Introduction The prolonged legal dispute between the Estate of Michael Jackson and the Internal Revenue Service (IRS) offers invaluable insights for valuation practitioners, particularly in the realm of business interest valuation for estate and gift tax purposes. The case revolved around the valuation of Jackson’s image and likeness, and his interests in two music publishing …
Estate of Warne v. Commissioner of Internal Revenue, a decision by the United States Tax Court on February 18, 2021 (“Estate of Warne”), offers essential insights into tax compliance valuation. This case dealt with the valuation of a closely held business and the proper calculation of estate taxes, highlighting the significance of proper documentation, valuation …
Gift & Estate Tax Compliance: Documentation, Valuation Techniques & Expert Testimony Read More »
Estate and gift tax valuation plays a pivotal role in tax planning by determining the fair market value of transferred property. Inaccurate valuations can lead to costly disputes with the Internal Revenue Service (IRS) and potentially result in penalties and interest under IRC Section 6501. The following article highlights the importance of meticulous and detail-oriented …
Post-Valuation-Date Events in Estate & Gift Tax: Lessons from CCA 202152018 Read More »
Gift transfers of assets during one’s lifetime can be an effective strategy to minimize estate size and reduce tax liabilities. However, careful planning is essential to ensure alignment with the transferor’s goals and compliance with tax regulations. The Nelson v Commissioner, 2021 U.S. App. LEXIS 32741 (“Nelson v. Commr.”) case study emphasizes the importance of …
Valuation is a crucial process in determining the fair value or fair market value of an asset or equity. Under federal tax laws, tax valuation encompasses various aspects, including 409a codification, gift and estate tax valuation, purchase price allocation, goodwill accounting valuation, and more. This in-depth article examines the factors that influence estate and gift …
Expert Analysis: Factors Affecting Estate & Gift Tax Valuations by Eton Venture Services Read More »
Introduction In the Estate of Aaron Jones v. Commissioner, T.C. Memo 2019-101, the United States Tax Court addressed the issue of tax affecting in the valuation of closely-held businesses for estate and gift tax purposes. This decision marked a significant departure from prior Tax Court rulings on the issue and has important implications for valuation …
U.S. Tax Court Advances Tax Affecting in Estate of Aaron Jones v. Commissioner Read More »
The landmark case of Kress v. United States, decided on March 26, 2019, has significantly impacted the field of business valuation, particularly in regard to valuing pass-through entities like S corporations. The U.S. District Court’s ruling in this case has strengthened the case for tax affecting when valuing pass-through entities, a practice that has long …
Kress v. United States: Tax Affecting in Valuation of Pass-Through Entities Gains Ground Read More »
The recent Tax Court ruling in the estate and gift tax case, Estate of Powell v. Commissioner, introduced a novel approach to address the double inclusion problem in valuation. The court sided with the Internal Revenue Service (IRS) and ruled that the value of assets transferred from the decedent to a family limited partnership (FLP) …
Tax Court Ruling Reshapes Valuation Methods in Estate & Gift Tax Cases Read More »
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