This appeal in a California court involved a dispute over an appraisal of the plaintiffs’ 15% interest in a grocery store the defendant operated. The plaintiffs alleged that the award of the superior court was obtained by fraud and that the arbitrator prejudiced their rights.
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Brief - Petitioner's Objections w/ Affidavits - Estate of Reichardt v. Commissioner
Taxpayer's objections filed in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).
Brief - Petitioner's Opening Brief - Estate of Reichardt v. Commissioner
This is the opening brief filed by the taxpayer in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).
Brief - Petitioner's Response to Brief For Respondent - Estate of Reichardt v. Commissioner
This is the taxpayer's response to the IRS brief in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).
Valuation Report - James M. Walter Jr., DDS, MS, PA
Valuation report of Robert N. Pulliam regarding the dental practice of James M. Walter Jr., DDS, MS, PA, as done in Aug. 16, 1996.
Valuation Report - Skyway Communications Holding Corp. and Subsidiary
Illustrative example of a valuation report as filed with the SEC for Skyway Communications Holding Corp. and Subsidiary ...
Valuation Report - Straight Arrow Publishers Inc.
The case involves the appraised value of the common stock of Straight Arrow Publishing, whose primary product is Rolling Stone magazine.
Highlights & Trends 4Q 2006
The last six months have seen a flurry of decisions from a variety of courts addressing whether it is appropriate to tax-affect the earnings of an S corporation. Tax-affecting means reducing S corporation earnings for taxes that are not paid at the corpor ...
Highlights & Trends 2Q 2006
Appraisers often ask about cases involving the quantification of damages in personal injury cases. Generally, personal injury actions with substantive forensic accounting issues don’t arise with any degree of frequency. Therefore, it is noteworthy that th ...
Highlights & Trends 1Q 2006
The valuation of contingent assets has frequently posed problems for courts to resolve. These assets rarely have any present monetary value on the valuation date, but value may or may not be realized in the post-divorce world through the efforts expended ...
Highlights & Trends 3Q 2005
Over the past quarter (the third quarter of 2005), the courts have handed down many instructive decisions of import across the valuation and litigation niches.
Highlights & Trends 3Q 2004
In this column, we will discuss highlights from the important decisions handed down in the third quarter of 2005 as well as look at trends in recent decisions across the jurisdictions and practice areas.
Highlights & Trends 2Q 2005
Some very interesting opinions across the spectrum of niche areas were issued this past quarter (the second quarter of 2005).
Highlights & Trends 4Q 2004
The courts across the U.S. have been very active in the fourth quarter of 2004. They handed down decisions impacting business valuation in all its niche markets.
Field Service Advice 200143004
Field Service Advice 200143004. The issues were: (1) Whether donor’s family corporation (FC) lacks economic substance and should be disregarded for gift tax purposes; (2) Whether donor made a gift of ...
Revenue Ruling 83-120
Rev. Rul. 83-120 Section 2512. -- Valuation of Gifts 26 CFR 25.2512-2: Stocks and bonds. (Also Sections 305, 351, 354, 368, 2031; 1.305-5, 1.351-1, 1.354-1, 1.368-1, 20.2031-2. ) 1983-2 ...
Prop. Treas. Reg. 1.1041-2 v.
The IRS proposed regulations to clarify the application of IRC sec. 1041. They apply only to stock redemption in which the non-transferor spouse directly owns stock in the redeeming corporation immediately before or after the redemption. The regulation ...
Technical Advice Memorandum 199938005
PRIVATE RULING 199938005 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) o ...
Revenue Procedure 2002-13
The full text of Revenue Procedure 2002-13 can be read here .
Technical Advice Memorandum 9723009
PRIVATE RULING 9723009 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code." Sect ...
IRS Valuation Training for Appeals Officers
Department of the Treasury Internal Revenue Service Valuation Training for Appeals Officers Coursebook This material was described specifically for training purposes only. Under no circumstances should the contents be used or cited as authority for setting or sustaining a technical position. Training 6126-002 (Rev. 05-97) TPDS 87221R Internal Revenue Service Mission The purpose of the IRS is to collect the proper amount of tax revenues at the least cost to the public, and in ...
Technical Advice Memorandum 9730004
PRIVATE RULING 9730004 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code."
IRC § 1033
LEXSTAT IRC sec. 1033 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12 ...
Treas. Reg. § 1.701-2: Anti-abuse rule
WAIS Document Retrieval[Code of Federal Regulations] [Title 26, Volume 8] [Revised as of April 1, 2001] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.701-2] [Page 309-319 ...
Technical Advice Memorandum 9842003
PRIVATE RULING 9842003 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) o ...
IRC § 2036 - Transfers with retained life estate
*** CURRENT THROUGH P.L. 106-580, APPROVED 12/29/00 *** SUBTITLE B. ESTATE AND GIFT TAXES CHAPTER 11. ESTATE TAX SUBCHAPTER A. ESTATES OF CITIZENS OR RESIDENTS PART III. GROSS ESTATE IRC S ...