FCG E-Flash 18:1 Estate of Giustina v. Commissioner

E-Flash 18:1   As is often the case with noncontrolling ownership interests in asset-intensive, agricultural-based entities (e.g., timberland, farms, ranches), the discounts from a pro rata share of 100% of the equity can be quite severe under the… Read More
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Categories: FCG E-Flash

FCG E-Flash 17:1 Estate of Giustina v. Commissioner

E-Flash 17:1 The business valuation profession has failed to adequately educate the Tax Court on the issue of tax affecting (or not) the income stream of PTEs. More specifically … Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 16:1 Estate of Richmond V Commissioner

E-Flash 16:1  To determine the value of the decedent’s 23.44% interest in Pearson Holding Co. (“PHC”) at the time of death, the court resolved the following disputes …    Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 15:3 Mountanos V. Commissioner

E-Flash 15:3   While not a primary focus of the case facts or ruling, the court’s failure to recognize the testimony of an untrained expert having no relevant professional credentials provides taxpayers and their professional advisors valuab… Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 15:1 Estate of James A. Elkins, Jr. v. Commissioner

E-Flash 15:1 In a case of great interest to appraisers of all stripes, James A. Elkins, along with his children, owned fractional interests in 64 pieces of art, some of which were from famous artists. Upon his death in 2006, his estate valued his… Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 14:4 Estate of Alfred J. Richard v. Commissioner

E-Flash 14:4 In an unusual case, a wife owning preferred shares in a closely-held company predeceased her husband. Almost six years after her husband’s death, his personal representatives discovered the wife’s will 13 years after her death… Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 14:3 Estate of George H. Wimmer v. Commissioner

E-Flash 14:3 The Tax court was tasked with determining if gifts of limited partnership interests transferred by the Decedent between 1996 and 2000 qualified for the Federal gift tax annual exclusion under §2503(b). Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 14:2 Joseph Mohamed Sr. v. Commissioner

E-Flash 14:2 Having become a successful real estate investor and developer, Joseph Mohamed, Sr. and his wife Shirley planned to use their wealth to assist certain charities after their death. They established a charitable remainder unitrust (CRUT)… Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 14:1 Joanne M. Wandry, Donor, Petitioner v. Commissioner

E-Flash 14:1 In an important gift tax case involving transfers among family members, the Tax Court determined that transfers of closely-held business interests were specific dollar amount transfers rather than transfers of fixed percentage interests… Read More
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Categories: FCG E-Flash
Tags: Court Case

FCG E-Flash 13:14 Estate Of Liljestrand V Commissioner

E-Flash 13:14 In yet another bad facts case (from the taxpayer’s perspective), the value of assets contributed to an FLP were includable in the Decedent’s estate under IRC § 2036(a). In particular, the Decedent failed to provide a non-ta… Read More
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Categories: FCG E-Flash
Tags: Court Case

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