This note questions the propriety of allowing discounts to reflect lack of control where spouses enjoyed joint control over undivided interests in a majority block of shares. The issue is examined in light of existing case law and by reference to Washington community property law and federal estate taxation policies. The note concludes that, although Lee is not contrary to any explicit provision in the Internal Revenue Code, discounting a deceased spouse\u27s share of a community owned majority block neither accurately reflects the degree of control its owners enjoyed nor effectively taxes wealth transfers at death
While residing with his wife in California, decedent purchased stock, which under California law bec...
Decedent, a Texas resident, provided that if his wife elected to take under his will she would recei...
This article traces the evolving judicial interpretation of the “adequate and full consideration” ex...
Early cases involving the government\u27s invocation of section 2036(a) to combat the use of family ...
In the case of U.S. v. Merrill, 211 F.2d 297, (9th Cir. 1954), the court held that when a wife dies ...
In the case of U.S. v. Merrill, 211 F.2d 297, (9th Cir. 1954), the court held that when a wife dies ...
The federal estate and gift taxes levy on the gratuitous transfer of wealth by both testamentary and...
In Estate of John Q. Strange, there was an agreement between two brothers, engaged in business in a ...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on pr...
It appears that Heasty v. United States has eliminated the previous uncertain estate tax consequence...
Decedent, a Texas resident, provided that if his wife elected to take under his will she would recei...
While residing with his wife in California, decedent purchased stock, which under California law bec...
Owners of close corporations have for many years entered into agreements with each other requiring a...
Covers cases on the surrender value of community insurance subject to inheritance tax and on disting...
While residing with his wife in California, decedent purchased stock, which under California law bec...
Decedent, a Texas resident, provided that if his wife elected to take under his will she would recei...
This article traces the evolving judicial interpretation of the “adequate and full consideration” ex...
Early cases involving the government\u27s invocation of section 2036(a) to combat the use of family ...
In the case of U.S. v. Merrill, 211 F.2d 297, (9th Cir. 1954), the court held that when a wife dies ...
In the case of U.S. v. Merrill, 211 F.2d 297, (9th Cir. 1954), the court held that when a wife dies ...
The federal estate and gift taxes levy on the gratuitous transfer of wealth by both testamentary and...
In Estate of John Q. Strange, there was an agreement between two brothers, engaged in business in a ...
Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other...
In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on pr...
It appears that Heasty v. United States has eliminated the previous uncertain estate tax consequence...
Decedent, a Texas resident, provided that if his wife elected to take under his will she would recei...
While residing with his wife in California, decedent purchased stock, which under California law bec...
Owners of close corporations have for many years entered into agreements with each other requiring a...
Covers cases on the surrender value of community insurance subject to inheritance tax and on disting...
While residing with his wife in California, decedent purchased stock, which under California law bec...
Decedent, a Texas resident, provided that if his wife elected to take under his will she would recei...
This article traces the evolving judicial interpretation of the “adequate and full consideration” ex...