Pluris Valuation Advisors’ Valuation Case Alerts are published on an irregular schedule, whenever the Tax Court or higher courts issue decisions on fair market value matters, or when there are new IRS rulings or other news of interest to our private clients and their other advisors.
To sign up to receive our Valuation Case Alerts in your email inbox, please register by entering your email in the header above and clicking the “Subscribe” button.
What a Waffle! As a waitress at the Waffle House in Grand Bay, Alabama, Tonda Lynn Dickerson had a regular customer, Edward Seward, who was known as a generous, albeit… more
Kite Stringing the IRS Along?Estate of Kite Deploys Private Annuities to Reduce the Estate Tax HitIn early 2001 Virginia V. Kite was 74 years old and, while not terminally ill,… more
Formula clauses have become a popular estate planning tool, and for very good reasons. After all, when making gifts, the donor is faced with an unpleasant source of risk: valuation.… more
The fact pattern in Wimmer v. Comm’r, TC Memo 2012-157, proved that the Wimmers’ annual exclusion gifts were present interest gifts and not future interest gifts. Thus, the gifts were qualified… more
It is ancient wisdom that “you can’t beat something with nothing.” It’s also well established that it’s best to have a backup plan when what you’ve set out to do… more
Stone v. Comm’r, TC Memo 2012-48 is yet another confirmation that when structured correctly, the taxpayer typically defeats the IRS in a Section 2036 case. BackgroundJoanne Stone (“Decedent”) and her… more
In Pierre v. Comm’r, TC Memo 2010-106, the IRS prevailed on the step transaction doctrine. However, with no appraisal fire power to back it up, the Service’s win ultimately fizzled… more
The petitioners in this case, Dr. Ben Alli and Shaki Alli, made a charitable donation of an apartment building to Volunteers of America in September 2008. At the time of… more
Liljestrand v. Comm’r, TC Memo 2011-259 is another bad facts case that propelled the IRS in a Section 2036 attack, and resulted in an approximate $2.6 million federal estate tax… more
In our currently stressed economic circumstances there may be a parent or two who feels they are not quite enjoying their home as much as before, due to the presence… more
Planning With SPAC Securities Taking Advantage of New Discounting Opportunities Capital markets statistics show it: The SPAC, or Special Purpose Acquisition Company, is the new initial public offering. For advisors… more
New 2704(b) Regulations – Return of Family Attribution? In an otherwise slow news season this summer, there’s been one theme that has caused excitement among estate planners: the prospect of… more
The End of The Road for Economic Benefit Split-Dollar Transactions? There are a great number of disputes, at varying stages of audit, appeals, or litigation, making their way towards Tax… more
In Adler v. Comm’r, TC Memo 2011-28, the IRS prevailed in a Section 2036 attack, and eliminated fractional interest discounts applied to an estate with a ranch property. BackgroundOn December… more
Gary T. Hurford passed away on April 8, 1999. He was survived by his wife Thelma and three children. Ms. Hurford passed away on February 19, 2001.Mr. Hurford had a… more
In Estate of Holliday, decided March 17,2016, the IRS won a small (dollar-wise) yet meaningful victory on the Sec. 2036 retained interest issue. The case is instructive, since the facts were not… more
For LISI: EXECUTIVE SUMMARY: Petitioner is denied $33.0 million tax deduction in its entirety because it left the “Donor’s cost or other adjusted basis” field blank on Form 8283. The… more
In Estate of Streightoff (TCM 2018-178), the IRS successfully argued the 89% interest in an FLP included in the estate was a limited partner interest, and not an assignee interest. The Court looked… more
In Ludwick v. Comm’r, TC Memo 2010-104, the Service struck a major blow for its favored approach to undivided interests, not only winning acceptance of its “cost to partition” approach, but… more
In Jensen v. Comm’r, TC Memo 2010-182, the estate prevailed on the discount for the Built-in-Gains (“BIG”) tax when determining the fair market value (“FMV”) of the estate’s interest in a company… more
“Intent to Terminate” Split-Dollar Arrangement Wins the Day for the IRS in Morrissette v. Comm’r Recently, in Morrissette v. Comm’r (TCM 2021-60), the Tax Court finally arrived at a first, long-awaited, decision on… more
Economic Benefit “Split-Dollar” Transaction Passes Crucial Test in Tax Court Estate of Morrissette Wins First Round in Court Inter-generational split-dollar transactions have become a popular way for families to purchase… more
In Estate of Franklin Z. Adell, Deceased, Kevin R. Adell, Temporary Co-Personal Representative v. Commissioner of Internal Revenue, T.C. Memo 2014-155, released yesterday, the issues to be determined by the Court… more
In Davis, taxpayers are “whipsawed” for a $23.3 million tax deficiencyIn Allen L. Davis, et al v. Comm’r1, TC Memo 2011-286, the IRS applied a section 83 attack on illiquid stock… more
Last week, we got another lesson in the value of proper appraisals of charitable donations. In Chrem v. Comm’r,[1] the initial tax filings failed to comply with the appraisal requirements, but the… more
“Tax Affecting” Allowed Regarding the Vanderbilt’s Biltmore Estate Cecil v. Commissioner provides insights on how to weigh evidence on valuation discounts By Espen Robak, CFA Ever since Gross,[1] the Tax Court has… more
In Richmond,[i] released yesterday, the Tax Court (1) contributed anew to the controversy over how the contingent tax liability for built-in capital gains should be valued; (2) set in motion forces… more
In Estate of Hilde E. Erickson, TCM 2007-207 (April 30, 2007), the IRS determined a $734,599 Federal gift tax and a $718,320 Federal estate tax deficiency of the estate of Mrs.… more
In Estate of Anne Y. Petter et al. v. Commissioner, No. 10-71854 (9th Cir. 2011), the Court affirmed a decision by the Tax Court[i] that allowed for the use of a “formula… more