40% 'Aggregate' Discount: Marketability, Control, and Unrealized Capital Gains
The IRS determined that decedent's estate owed amounts for estate tax and gift tax deficiencies.
5th Circuit Acknowledges Substantial Built-In Tax Liability on Timber Property
The issue on appeal was whether the Tax Court erred in the valuation of closely held stock and improperly denied a full discount for capital gains liability.
Gross v. Commissioner (II)
Issues involved tax affecting of the discounted cash flows of the company and the size of the marketability discount.
0% Reduction for Tax Affecting Affirmed
The 6th Circuit affirmed the Tax Court’s valuation of gifted minority interests in a closely held S corporation.
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GETTING MONEY OUT OF THE FAMILY BUSINESS—AVOIDING CONFLICTS BETWEEN THE INCOME TAX AND THE TRANSFER TAX
Richard B. Robinson ALI-ABA Course of Study Materials: Estate Planning for the Family Business Owner , March 2001, Volume I This volume is divided into 22 chapters. Of particular interest to o ...
Estate of Dailey v. Commissioner (I)
At issue are the valuation of certain retained and gift interests in a Family Limited Partnership (FLP).
Buy-Sell Agreements Fail Lauder II Test and Are Considered Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
Gow v. Commissioner (II)
At issue is whether that the Tax Court improperly val-ued the plaintiff's shares of stock in Williamsburg Vacations, Inc. ("WVI") for tax purposes.
4th Circuit Affirms Gow v. Commissioner
This income tax case was appealed from the U.S. Tax Court. (The lower court case was abstracted in the May 2000 issues of both BVU and J&L ...
Estate of Jameson v. Commissioner
At issue is whether the Tax Court erred in valuing assets of Johnco, Inc. ("Johnco"), a holding company that is part of the estate.
5th Circuit Reverses Tax Court's Capital Gains Discount 'Model'
The issue on appeal was whether the Tax Court erred in the valuation of closely held stock and improperly denied a full discount for capital gains liability.
Shackleford v. United States
At issue is whether a statutory anti-assignment restriction on lottery payments justifies departure from the Department of Treasury's annuity tables when determining the asset's present value.
Fair Market Value Trumps IRS Valuation Tables
In 1987, Thomas J. Shackleford bought a California Lottery ticket for $1 and won the jackpot.
The Anatomy of Valuing Stock in Close Held Corporations: Pursuing the Phantom of Objectivity into the New Millennium
Stephen J. Leacock Columbia Business Law Review , 2001 Issue This article discusses several valuation approaches followed by the courts, particularly with valuation disputes concerning close ...
Estate of O'Neal v. United States
At issue is the valuation date of the value of a deduction claimed by the estate.
11th Circuit Holds Claims Against Estate Do Not Include Post-Death Events
This is an appeal from the United States District Court for the Northern District of Alabama.
Estate of Schwan v. Commissioner
At issue is the valuation of the decedent's stock in a closely-held corporation for purposes of computing the gross estate and the allowable charitable deduction under Federal tax laws.
Redemption Agreement Did Not Affect Value of Decedent's Estate
The petitioners in this case, decedent's estate and a charitable foundation (the Martin M. Schwan Foundation), challenged the IRS' determination that the estate had a tax deficiency based on a bequest to the foundation and that the foundation was liable as a transferee.
Valuation uncertainty continues – the Ninth Circuit reverses the Tax Court
The recent enactment of the Economic Growth and Tax Relief Reconciliation Act of 2001 1 (Act) poses new challenges and opportunities alike to owners of substantial estates and their profess ...
Estate of Cook v. Commissioner
At issue is the value at decedent's date of death of her interest in a limited partnership.
Tax Court Values Partnership Interest in Future Lottery payments
This estate tax case concerns 19 annual installment payments of lottery winnings to a limited partnership in which the decedent held a 2% general partnership interest and a 48% limited partnership interest.
Estate of True v. Commissioner
1Cases of the following petitioners are consolidated herewith: Jean D. True, docket No. 3408-98 and Estate of H.A. True, Jr., Deceased, H.A. True, III, Personal Representative, docket No. 3409-98. T.C. Memo. 2001-167 UNITED STATES TAX COURT ESTATE OF H.A. TRUE, JR., DECEASED, H.A. TRUE, III, PERSONAL REPRESENTATIVE, AND JEAN D. TRUE, ET AL.1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10940-97, 3408-98, Filed July 6, 2001. 3409-98. Buford P. Berry, Emily A. Parker ...
Buy-Sell Agreements Are Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
Buy-Sell Agreements Do Not Control for Estate Tax Purposes
The Tax Court considered whether buy-sell agreements controlled the value of the business interests the decedent held for estate and gift tax purposes.