| 1 | 6/19/1997 | BVLaw |
Wheeler v. United States
Issue is whether sale of remainder interest for less than value of full fee simple interest in ranch constitutes adequate consideration for the purposes of section 2036(a).
United States Court of Appeals 5th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (14,645 words)
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| 2 | 3/15/2005 | BVLaw |
Estate of Bongard v. Commissioner
In this estate tax case, there were two issues: whether pursuant to IRC Sections 2035(a) and 2036(a), (b) the gross estate should have included: (1) shares Wayne Bongard (decedent) transferred to a holding company and (2) the holding company's membership...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (28,469 words)
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| 3 | 5/20/2004 | BVLaw |
Kimbell v. US
At issue is the transferral of assets for an interest in partnership (operated by decedent's son) was a "bona fide" sale or not, thus incurring Section 2036 consideration.
United States Court of Appeals 5th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (6,711 words)
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| 4 | 7/13/1999 | BVLaw |
Estate of Magnin v. Commissioner of Internal Revenue
At issue is the value of the remainder interest of the family corporation and the life and voting interest of the stock in the family corporations.
United States Court of Appeals 9th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (4,887 words)
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| 5 | 3/26/2008 | BVLaw |
Estate of Mirowski v. Commissioner
Tax court upholds near-death transfers of family limited partnership.
United States Tax Court Federal Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (21,763 words)
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| 6 | 9/1/2004 | BVLaw |
Turner v. Commissioner
This issue in this case is the court's denial of FLP recognition.
United States Court of Appeals 3rd Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (10,708 words)
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| 6 | 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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| 8 | 11/26/1996 | BVLaw |
Estate of D'Ambrosio v. Commissioner
Issue is whether entire fee simple value of stock was part of gross estate even though the decedent had sold her remainder interest in the stock for its fair market value.
United States Court of Appeals 3rd Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (6,831 words)
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| 9 | 3/19/2001 | BVLaw |
Estate of Cyril Magnin v. Commissioner, T.C.
Click here for full text (pdf) of Estate of Magnin v. Commissioner . requires Acrobat Reader .
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (12,364 words)
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| 9 | 5/5/1997 | BVResearch |
The Art of Making Uncle Sam Your Assignee Instead of Your Senior Partner: The Use of Family Partnerships in Estate Planning(s)
THE ART OF MAKING UNCLE SAM YOUR ASSIGNEE INSTEAD OF YOUR SENIOR PARTNER: THE USE OF FAMILY PARTNERSHIPS IN ESTATE PLANNING(c) By S. Stacy Eastland I. SYNOPSIS OF OUTLINE The primary purpose of...
Stacy S Eastland
Articles (70,992 words)
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| 11 | 2/12/2001 | BVLaw |
Estate of Cyril I. Magnin (Magnin III) v. CIR
The Tax Court considered whether a decedent received adequate and full consideration under an agreement executed in 1951. The Ninth Circuit determined that the proper measure of valuing adequate and full consideration was the actuarial value of the remain...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (13,581 words)
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| 12 | 12/14/2009 | BVLaw |
Estate of Black v. Comm’r
Tax Court finds excellent facts regarding formation and legitimate, non-tax purpose of a family limited partnership, sufficient to value its interests at a stipulated discount for purposes of estate tax.
United States Tax Court Federal Circuit US, Action: Federal Taxation
Full Text of Court Cases (20,692 words)
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| 13 | 2/1/2007 | BVResearch |
Responding to the continuing Section 2036 attack on Family Limited Partnerships
CICBV/ASA Sixth Conference, October 2006, Toronto, Canada...
David L Starbuck
Presentations (19,861 words)
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| 14 | 5/15/2002 | BVLaw |
Estate of Harper v. Commissioner
Tax Court ruled that 100 percent of the property within the partnership, despite the fact that the partnership was validly formed, was includable in the gross estate under Sec. 2036 (a).
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (17,070 words)
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| 15 | 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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| 16 | 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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| 17 | 9/14/2007 | BVLaw |
Estate of Bigelow v. Comm’r
Court denies discount for family limited partnership in estate tax case where FLP made funds available to decedent and failed to observe partnership formalities and legitimate business.
United States Court of Appeals 9th Circuit, Action: Estate and Gift Taxation
Full Text of Court Cases (9,286 words)
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| 17 | 1/24/1996 | BVLaw |
Estate of Cyril I. Magnin (Magnin I) v. CIR
The Tax Court clarified the definition of 'Fair Market Value' when it warned that the hypothetical sale should not be separated from the actual facts that would affect the value of the subject company's stock.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (8,575 words)
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| 19 | 1/16/2007 | BVResearch |
The Continuing §2036 Attack on Family Limited Partnerships
Presented at the 2006 AICPA National Business Valuation Conference in Austin, Texas (December 3-5, 2006...
Ronald L Seigneur
Presentations (8,722 words)
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| 19 | 2/18/2004 | BVLaw |
Estate of Abraham v. Commissioner
At issue is the inclusion of certain properties in the gross estate which decedent had transferred while alive but from which retained generated income.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (7,181 words)
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