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13/25/2009BVResearch
Commissioner v. Estate of Jelke: Briefs on Writ of Certiorari to the U.S. Supreme Court (2008)
Commissioner v. Estate of Jelke: Briefs on Writ of Certiorari to the U.S. Supreme Court (2008...
Articles
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24/19/2002BVLaw
Todd v. Commissioner
The only issue in this case was whether the petitioner, who formed a nonprofit corporation, was entitled to charitable deductions.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases  (4,671 words)
32/1/2003BVResearch
C Corporations with Appreciated Assets: Valuation Discount for Built-In Capital Gains
The valuation of a C corporation is a common valuation assign-ment. Experienced analysts routinely value 100 percent of the stock of a C corporation for such purposes as: merger and acquisition pricing; estate and gift tax planning and compli-REVIEW OF...
Jacob Roosma
Willamette Insights  (4,630 words)
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48/18/1998BVLaw
Eisenberg v. Commissioner
At issue is the valuation reduction for capital gains tax liabilities of appellant's gifted shares of stock.
United States Court of Appeals 2nd Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases  (5,894 words)
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45/5/1997BVResearch
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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64/7/1999BVLaw
Donors Liable for Gain in Appreciated Stock under Anticipatory Assignment of Income Doctrine
The U.S. Court of Appeals for the Ninth Circuit applied the anticipatory assignment of income doctrine and determined that the taxpayers were liable for the capital gain on appreciated stock they donated to a charitable organization. The stock was transf...
Court Case Digests  (551 words)
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64/7/1999BVUpdate
The U.S. Court of Appeals for the Ninth Circuit applied the anticipatory assignment of income doctrine and determined that the taxpayers were liable for the capital gain on appreciated stock they donated to a charitable organization. The stock was transf...
, Action: Estate and Gift Taxation
Legal and Court Case Update  (551 words)
Business Valuation Update
81/29/2009BVLaw
Estate of Litchfield v. Commissioner
Tax Court considers determination of discounts for embedded capital gains taxes, lack of control, and lack of marketability for estate’s interests in two closely held companies, one owning primarily farm land and the other marketable securities.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases  (5,594 words)
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91/6/1999BVLaw
Pope & Talbot, Inc. v. Commissioner of Internal Revenue
At issue is the fair market value of the property the plaintiff distribtued to a limited partnership.
United States Court of Appeals 9th Circuit US, Action: Federal Taxation
Full Text of Court Cases  (5,171 words)
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105/31/2005BVLaw
Estate of Jelke v. Commissioner
The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value, and the appropriate discounts for lack of marketability and control.
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases  (9,809 words)
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114/28/2008BVResearch
The Jelke Reversal
The Jelke Reversal Teleconference Presentation and Transcript January 17th, 2008 Moderator: Lucretia Lyons Panelists: John W. Porter, Partner at Baker Botts, L.L.P. William H. Frazier, Partner at Howard Frazier Barker Elliott, In...
Teleconference Transcripts  (14,681 words)
114/7/1999BVLaw
Michael Ferguson, et al. (Ferguson II) v. CIR
The U.S. Court of Appeals for the Ninth Circuit applied the anticipatory assignment of income doctrine and determined that the taxpayers were liable for the capital gain on appreciated stock they donated to a charitable organization. The stock was transf...
United States Court of Appeals 9th Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases  (5,846 words)
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135/28/2008BVLaw
Disputes Over Discounts Complicates Stock Valuation in Divorce
Disputes over discounts, inclusion of assets, complicates valuation of closely-held stock in divorce.
Court of Appeals
Court Case Digests  (404 words)
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137/14/1999BVLaw
Mayhew v. Mayhew
At issue is the appreciation value of husband's stock as marital property.
Supreme Court West Virginia US, Action: Marital Dissolution
Full Text of Court Cases  (10,005 words)
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151/18/2005BVLaw
Jenny Warren v. Claude Warren
The Maine Supreme Court affirmed the trial court’s determination that the entire amount of appreciation in a separate property minority interest in a firearms manufacturer should be characterized as marital property even though the owning spouse was remov...
Supreme Court Maine US, Action: Marital Dissolution
Full Text of Court Cases  (4,937 words)
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168/5/2002BVLaw
Norton Co v. Smyth
The issue, in this case of first impression in Washington, was the propriety of discounts for lack of marketability and built-in capital gains in a dissenters' rights proceeding.
Court of Appeals Washington US, Action: Dissenting Shareholder
Full Text of Court Cases  (7,152 words)
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172/4/2000BVLaw
Carol M. Read, et al. v. CIR
The full Tax Court considered whether a corporate redemption of a former spouse's stock in the parties' business pursuant to a divorce qualified for nonrecognition treatment under IRC sec. 1041. The Tax Court specifically considered the legal standard to...
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases  (24,103 words)
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185/28/2008BVUpdate
Disputes over discounts, inclusion of assets, complicates valuation of closely-held stock in divorce.
Court of Appeals Ohio US, Action: Marital Dissolution
Legal and Court Case Update  (404 words)
Business Valuation Update, May 2008
1811/15/2007BVLaw
Estate of Jelke v. Comm’r
Eleventh Circuit rejects Jelke and adopts dollar-for-dollar discount for contingent capital gains tax liability.
United States Court of Appeals 11th Circuit, Action: Estate and Gift Taxation
Full Text of Court Cases  (13,823 words)
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183/20/2006BVResearch
How to Discount for Trapped-In Capital Gains Tax
August 2004 Teleconference Transcript; Panel: Shannon Pratt (Moderator), William Frazier, Mark Lee, and Eric Nath...
Teleconference Transcripts  (14,098 words)
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