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Estate and Gift Valuation E-Flash Updates
Valuation information, of interest to: attorneys, business owners, and tax
professionals.
Issue 11:6
: Estate of Samuel P. Black, Jr., Deceased, Samuel P. Black, III, Executor,
et al v. Commissioner, 133 T.C. No. 15 Docket Nos. 21388-05, 23191-05,
23516-06, December 14, 2009
Effective estate planning significantly reduced the
Decedent’s estate tax liability. Key points in the ruling included:
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Transfers of closely-held stock from the gross estate to an FLP were for
full and adequate consideration and therefore not includable in the gross
estate. - Passive entities can be created for legitimate and significant
nontax reasons (including preventing the sale of assets by grandsons who
lacked ambition and preventing distribution to a spouse in an anticipated
divorce proceeding). - Date of death of surviving spouse was reasonable
date for funding of QTIP trust given death of husband and wife were close
together and estates were so intertwined. - Interest on a loan to pay
estate tax and associated fees was not deductible in this case. -
Significant portions of the Estate's attorney and exedutor's fees were
disallowed for one estate but includable in the other.
Issue 11:4
: Pierre v. Commissioner,
133 T.C. No. 2, August 24, 2009
The Tax Court was asked to determine whether
transfers of interests in a single-member LLC should be valued as direct
transfers valued as an undiscounted, proportionate share of the LLCs assets
or as transfers of interests in the LLC, thus being subject to valuation
discounts.
Issue 11:2 :
Miller v. Commissioner, T.C. Memo. 2009-119,
May 27, 2009
The Tax Court determined whether a discount was appropriate to apply to cash
and securities transferred to a family limited partnership.
Issue 11:1 : Litchfield v. Commissioner, T.C. Memo. 2009-21,
January 29, 2009
The
Tax Court calculated the discount for built-in capital gains taxes in a
recently converted “C” to “S” corporation, along with discounts for lack of
control, and lack of marketability.
Building Value Success through Collaboration, a
business valuation newsletter for business owners and the professionals who
advise them.
Volume 7 Issue 1
The "Value" of "Investments" in A/R and Inventory, Case Update - Jelke V.
Commissioner
Volume 4 Issue 3
Plan Now If You Intend To Sell Later, An IRS Audit And A Subsequent Event
Volume 4 Issue 1
Key Financial Metrics For Software Companies, Tips For Attorneys Working With A
Business Appraiser In Estate And Gift Settings
Volume 3 Issue 3 -
pdf format 96 kb
Collaborative Law And The Business Appraiser: A Common Sense Approach,
Exit Strategies For The Business Owner: Don't Let The Door Hit You On The
Way Out, Case Summary--Peracchio V. Commissioner
Volume 3 Issue 2
Four Ways To Falter In Being An "Expert" Expert, The
Family Limited Partnership--Still A Viable Financial Planning Tool, Case
Summary--Estate Of Helen A. Deputy
Volume 2 Issue 2 -
pdf format 86 kb
Basics And Benefits Of An Employee Stock Ownership Plan, Tips On
Drafting LLC/FLP Agreements, Fifth Circuit Reverses Tax Court Decision On
Partnerships
Volume 2 Issue 1
Business Value: Who, Why, And What World? Role Of Mergers And Acquisitions
Advisor, Gifts In A Family Partnership
Volume 2 Issue 1 Supplemental
Valuation For Financial Reporting
The newsletters are published in Adobe Acrobat pdf format.
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