Add to ORKGI. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1. Estate Tax and the Asset Valuation Rule … 2. Gift Tax and the Asset Valuation Rule III. Judicial Inroads into the Service’s Asset Valuation Rule … A. Estate of Bischoff v. Commissioner … B. Estate of Goldie Brown v. Commissioner … C. The Close Corporation Analogy IV. Discount Characteristics of Partnerships and the Close Corporation Analogy … A. Minority Interest Discounts … 1. Close Corporations … a. Rights under Local Law … 2. General Partnership Interests … 3. Limited Partnership Interests … B. Lack of Marketability Discounts … 1. Close Corporations … a. The Hypothetical Sale: Section 20.2031-1(b) and Revenue Ruling 59-60 … 2. Partnership...
Changes in valuation regulations mean higher values and increased taxes. The amendment itself and th...
There are three phases to the problem of arriving at a final dollar and cents valuation of a decease...
Sophisticated estate planning encompasses the concept of valuation discounting. Discounting can be a...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on pr...
Family partnerships have been become increasingly popular as a means of avoiding estate and gift tax...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
The discounts for lack of marketability and minority interest are crucial in reducing the value of t...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
The discounts for lack of marketability and minority interest are crucial in reducing the value of t...
This Note will first provide a brief background outlining the incidents of joint tenancy which make ...
This article traces the evolving judicial interpretation of the “adequate and full consideration” ex...
Today, discounts for co-ownership of interests in real estate are available generally and that has b...
Excerpt: “The authors of this article offer an overview of the pertinent cases—to reveal that the ta...
The authors argue that the goals of estate and gift taxation are not served by taxing closely held b...
Changes in valuation regulations mean higher values and increased taxes. The amendment itself and th...
There are three phases to the problem of arriving at a final dollar and cents valuation of a decease...
Sophisticated estate planning encompasses the concept of valuation discounting. Discounting can be a...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on pr...
Family partnerships have been become increasingly popular as a means of avoiding estate and gift tax...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
The discounts for lack of marketability and minority interest are crucial in reducing the value of t...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
The discounts for lack of marketability and minority interest are crucial in reducing the value of t...
This Note will first provide a brief background outlining the incidents of joint tenancy which make ...
This article traces the evolving judicial interpretation of the “adequate and full consideration” ex...
Today, discounts for co-ownership of interests in real estate are available generally and that has b...
Excerpt: “The authors of this article offer an overview of the pertinent cases—to reveal that the ta...
The authors argue that the goals of estate and gift taxation are not served by taxing closely held b...
Changes in valuation regulations mean higher values and increased taxes. The amendment itself and th...
There are three phases to the problem of arriving at a final dollar and cents valuation of a decease...
Sophisticated estate planning encompasses the concept of valuation discounting. Discounting can be a...