| 1 | 6/10/2002 | BVLaw |
Kerr v. Commissioner
Issue was whether restrictions in partnership agreements were "applicable restrictions" to be disregarded in valuing the transferred interests, precluding a marketability discount.
United States Court of Appeals 5th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (2,439 words)
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| 2 | 12/23/1999 | BVLaw |
Kerr v. Commissioner
At issue is the valuation of the FLP interests for federal gift tax purposes.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (8,979 words)
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| 3 | 2/28/2000 | BVLaw |
Taxpayers transferred FLP interests in form and substance
The first guidance on some of the tax issues facing family limited partnerships (FLPs) has been issued by the Tax Court in this gift tax case . The case dealt with a number of relevant issu...
United States Tax Court
Court Case Digests (1,972 words)
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| 4 | 2/28/2000 | BVLaw |
A gift for taxpayers and FLPs?
The first guidance on some of the tax issues facing family limited partnerships (FLPs) has been issued by the Tax Court in this gift tax case . The case dealt with a number of relevant issues includi...
United States Tax Court
Court Case Digests (1,785 words)
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| 5 | 6/30/2000 | BVLaw |
Harper v. Commissioner
At issue is whether, pursuant to section 2704(b), restrictions on the right to liquidate certain limited partnership interests in Harper Financial Co., L.P., should be disregarded.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (1,460 words)
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| 6 | 12/8/2000 | BVLaw |
IRS Released Its Positions Regarding Limited Liability Companies
The Internal Revenue Service stated its positions regarding the recapture of the value of assets transferred to a closely held LLC for gift and estate tax purposes. It holds that the economic substance doctrine applies, IRC sec. 2703(a) is applicable, IRC...
Court Case Digests (584 words)
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| 7 | 10/28/2000 | BVLaw |
Tax Court rejects IRS bid to overrule Kerr v. Commissioner
The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co., L.P., entered into by the decedent and his two children, were ap...
United States Tax Court
Court Case Digests (579 words)
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| 7 | 9/28/2000 | BVLaw |
Tax Court rejects IRS bid to overrule Kerr
The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co., L.P., entered into by the decedent and his two...
United States Tax Court
Court Case Digests (419 words)
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| 9 | 1/13/1999 | BVLaw |
Valuation Discounts Rejected When Liquidation Provision Is More Restrictive than State Law
This field service advice concluded that restriction on liquidations on liquidation contained in a family limited partnership agreement were more restrictive than the applicable Missouri state law, and thus, the restrictions should be disregarded for valu...
Court Case Digests (273 words)
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| 10 | 7/6/2001 | BVLaw |
Estate of True v. Commissioner
Click here (EstateofTruevCommissioner.pdf/550k) to download the full text of the court case in PDF format.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (79,337 words)
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| 11 | 8/22/2007 | BVLaw |
Litman v. United States
Federal claims court rejects IRS and others’ reliance on restricted stock studies to determine appropriate discount for lack of marketability for restricted stock, preferring taxpayer’s option-pricing and CAPM analysis.
United States Court of Federal Claims Federal Circuit US, Action: Federal Taxation
Full Text of Court Cases (36,784 words)
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| 11 | 8/22/2007 | BVLaw |
Litman v. United States
Federal Court of Claims prefers option-pricing models to quantify marketability discounts for large block of restricted Internet stock.
United States Court of Federal Claims Federal Circuit, Action: Estate and Gift Taxation
Full Text of Court Cases (36,784 words)
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| 13 | 8/28/2002 | BVLaw |
Fifth Circuit affirms Kerr; Partnership agreement restrictions do not preclude marketability discount
This case is the Fifth Circuit Court of Appeals' review of the Tax Court case, Kerr v. Commissioner , 113 T.C. No. 30 (U.S. Tax Ct. Dec. 23, 1999), abstracted by Mel Abraham in the February 2000...
United States Court of Appeals
Court Case Digests (518 words)
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| 14 | 11/17/2005 | BVLaw |
Estate of Doris F. Kahn v. CIR
The full Tax Court concluded that a discount was not applicable to individual retirement accounts (IRAs) to account for the built-in gains that would be taxable to estate or beneficiaries upon their distribution. It rejected various analogies to lottery p...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (7,844 words)
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| 14 | 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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| 14 | 10/27/1994 | BVLaw |
Estate of Luton v. Commissioner
Issues are value of 78-percent interest in Rancho San Juan, Inc., one-third interest in Dune Lakes, Ltd., and 41.9-percent interest in the Miramonte Liquidating Trust, and penalties for und...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (9,853 words)
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| 17 | 3/6/2001 | BVLaw |
Estate of Jones v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (7,478 words)
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| 17 | 11/30/2000 | BVLaw |
Knight v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (6,191 words)
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| 19 | 12/2/2004 | BVLaw |
Estate of HA True v. Commissioner
The issue in this tax case focused on the ability of the taxpayer’s restrictive buy/sell agreement to reduce the value of the family business by its terms.
United States Court of Appeals 10th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (22,061 words)
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| 19 | 12/23/1999 | BVLaw |
FLP’s Liquidation Provisions Must Be Considered When They Are Not More Restrictive than State Law
The Tax Court granted the Kerrs' motion for summary judgment. The issue in this case was whether the liquidation provisions contained in two partnership agreements were more restrictive than the applicable state law and, thus, were 'applicable restrictio...
Court Case Digests (457 words)
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