| 1 | 12/19/2005 | BVLaw |
Davis v. United States
Court assesses whether fair market value of non-marketable annuity varies from present value of IRC annuity tables...
United States District Court New Hampshire US, Action: Estate and Gift Taxation
Full Text of Court Cases (3,938 words)
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| 2 | 3/8/2001 | BVLaw |
Estate of Gribauskas v. Commissoner
At issue is whether an interest held at death by Paul C. Gribauskas (decedent), in 18 annual installments of a lottery prize, must be valued for estate tax purposes.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (8,883 words)
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| 3 | 6/13/2007 | BVLaw |
Davis v. United States
Second Circuit finds that although IRC annuity tables do not account for lack of marketability of lottery payments, the discount is not so substantial as to warrant departure therefrom.
United States District Court New Hampshire, Action: Estate and Gift Taxation
Full Text of Court Cases (3,800 words)
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| 4 | 12/11/2008 | BVLaw |
Estate of Hurford v. Comm’r
Tax Court disallows FLPs based on numerous bad facts, including poor drafting, delayed funding, and exchange of founder’s interests for a private annuity from the minority owners.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (17,272 words)
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| 5 | 1/28/2009 | BVLaw |
Negron v. U.S.
Sixth Circuit joins majority of federal courts in finding that IRS annuity tables are appropriate when valuing non-assignable lottery payments for estate tax purposes.
United States Court of Appeals 6th Circuit US, Action: Federal Taxation
Full Text of Court Cases (4,718 words)
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| 6 | 6/17/1998 | BVLaw |
Estate of Suzanne W. Cullison v. CIR
The Tax Court determined that the decedent did not receive adequate and full consideration when she transferred real property to her children in exchange for a private annuity. The court determined that the taxpayer's accountant provided them with faulty...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (6,149 words)
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| 7 | 5/9/2001 | BVLaw |
Patricia A. and John C. Schott v. CIR (Schott I)
The Tax Court concluded that grantor retained annuity trusts (GRATs) from the plaintiffs should be valued as single life annuities rather than dual life annuities. It reached this decision after considering the fact that the grantor of each trust retained...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (3,563 words)
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| 8 | 11/13/2003 | BVLaw |
Estate of Cook v. Commissioner
At issue is the classification of a lottery prize issued in annual payments as a private annuity, thereby being valued using annuity tables (by the Tax Court) and thus without discounts.
United States Court of Appeals 5th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (5,081 words)
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| 9 | 4/26/2005 | BVLaw |
Estate of Donovan v. U.S.
Federal district court (Mass.) finds that IRS annuity tables do not place "unreasonable or unrealistic" value on non-assignable lottery payments for purposes of assessing estate tax.
United States District Court Massachusetts US, Action: Federal Taxation
Full Text of Court Cases (5,666 words)
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| 10 | 7/29/1998 | BVLaw |
Estate of Thomas J. Shackleford (Shackleford I) v. United States of America
The U.S. District Court for the Eastern District of California considered whether unreceived lottery payments should be valued as a commercial annuity or as a private annuity including deviations from the annuity tables for lack of marketabilty. The cour...
United States District Court California US, Action: Estate and Gift Taxation
Full Text of Court Cases (4,264 words)
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| 11 | 5/9/2001 | BVLaw |
GRATs Valued as Single-Life Annuity
The Tax Court concluded that grantor retained annuity trusts (GRATs) from the plaintiffs should be valued as single life annuities rather than dual life annuities. It reached this decision after considering the fact that the grantor of each trust retained...
Court Case Digests (273 words)
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| 12 | 10/16/2002 | BVLaw |
Estate of Melvine B. Atkinson v. CIR
The U.S. Court of Appeals for the Eleventh Circuit determined that an estate may not make a charitable deduction for an amount passing from a charitable remainder annuity trust (CRAT) to the charity when the CRAT regulations are not followed from formatio...
United States Court of Appeals 11th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (2,817 words)
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| 13 | 7/28/2006 | BVLaw |
Lottery Winner Attempts Second Win on Discounted Present Value of Annuity
Court assesses whether fair market value of non-marketable annuity varies from present value of IRC annuity tables.
United States District Court
Court Case Digests (900 words)
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| 14 | 2/18/2003 | BVLaw |
Patricia Schott v. CIR (Schott II)
The U.S Court of Appeals for the Ninth Circuit reversed the Tax Court and concluded that grantor retained annuity trusts established for the life of the grantor and the life of the grantor’s spouse, if the grantor dies before the expiration of the GRAT, w...
United States Court of Appeals 9th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (1,843 words)
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| 15 | 8/28/2007 | BVLaw |
Two New Lottery Cases: The Odds of Discounting From Annuity Tables Decrease
Sixth Circuit finds that government annuity tables do not accurately reflect fair market value of lottery payments, and continues case for expert evidence. Second Circuit finds that although IRC annuity tables do not account for lack of marketability of...
United States District Court
Court Case Digests (1,254 words)
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| 16 | 4/28/2009 | BVLaw |
Lottery Case & Effect of Transfer Restrictions on Valuing Annuities
Sixth Circuit joins majority of federal courts in finding that IRS annuity tables are appropriate when valuing non-assignable lottery payments for estate tax purposes.
United States Court of Appeals
Court Case Digests (1,224 words)
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| 17 | 12/28/1995 | BVLaw |
Estate of Gordon B. McLendon (McLenson I) v. CIR
The U.S .Court of Appeals for the Fifth Circuit concluded that the Tax Court erred when it valued interests in a partnership as partnership interests rather than assignee interests. It determined that state law established the objective criteria for trea...
United States Court of Appeals 5th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (6,800 words)
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| 18 | 7/9/2001 | BVLaw |
Estate of Cook v. Commissioner
At issue is the value at decedent's date of death of her interest in a limited partnership.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (3,051 words)
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| 18 | 7/29/1998 | BVLaw |
Lottery Payments Must Be Valued as Private Annuities
The U.S. District Court for the Eastern District of California considered whether unreceived lottery payments should be valued as a commercial annuity or as a private annuity including deviations from the annuity tables for lack of marketabilty. The cour...
Court Case Digests (227 words)
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| 20 | 2/18/2003 | BVLaw |
Interest From Dual-Life Annuity Qualifies under Sec. 2702
The U.S Court of Appeals for the Ninth Circuit reversed the Tax Court and concluded that grantor retained annuity trusts established for the life of the grantor and the life of the grantor’s spouse, if the grantor dies before the expiration of the GRAT, w...
Court Case Digests (339 words)
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