Add to ORKGOver the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other than joint tenancy).1 Interests in real property held as community property have been eligible for a discount in value for unmarketability of the decedent’s fractional interest, at least since 1982.2 However, discounts for undivided interests in tenancy-in-common ownership of property otherwise were rejected until fairly recently.
A 1995 private letter ruling1 held that an undivided one-sixth interest in farm real estate that was...
At the time of enactment of special use valuation in 1976,1 no mention was made of the possibility o...
Traditionally, a substantial amount of farm property is transferred within the family. A major issue...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
Today, discounts for co-ownership of interests in real estate are available generally and that has b...
Before 1989, the courts were almost uniformly unwilling to allow a discount for unmarketability of a...
A decision by the Fifth Circuit Court of Appeals in 2014, Elkins v. Commissioner1 involving co-owner...
Until 1989, the Tax Court had rejected co-ownership or “fractionalization” discounts to real propert...
A pair of U.S. Tax Court cases, decided exactly one week apart, have raised questions whether the Ta...
Funding the marital and non-marital shares in a farm or ranch estate is always an important decision...
The rapidly escalating values of farmland1 (and some ranchland) in recent years has raised the quest...
Farm and ranch businesses for many years have been eligible for discounts for minority interest and ...
Although joint tenancy (and tenancy by the entirety in the few states where that form of co-ownershi...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
In recent years, family limited partnerships have gained in popularity for various reasons. Much of ...
A 1995 private letter ruling1 held that an undivided one-sixth interest in farm real estate that was...
At the time of enactment of special use valuation in 1976,1 no mention was made of the possibility o...
Traditionally, a substantial amount of farm property is transferred within the family. A major issue...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
Today, discounts for co-ownership of interests in real estate are available generally and that has b...
Before 1989, the courts were almost uniformly unwilling to allow a discount for unmarketability of a...
A decision by the Fifth Circuit Court of Appeals in 2014, Elkins v. Commissioner1 involving co-owner...
Until 1989, the Tax Court had rejected co-ownership or “fractionalization” discounts to real propert...
A pair of U.S. Tax Court cases, decided exactly one week apart, have raised questions whether the Ta...
Funding the marital and non-marital shares in a farm or ranch estate is always an important decision...
The rapidly escalating values of farmland1 (and some ranchland) in recent years has raised the quest...
Farm and ranch businesses for many years have been eligible for discounts for minority interest and ...
Although joint tenancy (and tenancy by the entirety in the few states where that form of co-ownershi...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
In recent years, family limited partnerships have gained in popularity for various reasons. Much of ...
A 1995 private letter ruling1 held that an undivided one-sixth interest in farm real estate that was...
At the time of enactment of special use valuation in 1976,1 no mention was made of the possibility o...
Traditionally, a substantial amount of farm property is transferred within the family. A major issue...