Second Circuit Reins in Section 2036 Mother Continuing to Share Property with Son Does Not Constitute "Enjoyment and Possession"By: Espen Robak, CFA of Pluris Valuation AdvisorsIn our currently stressed economic circumstances there may be a parent or two who feels...
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By: Espen Robak, Pluris Valuation Advisors 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. Hilde E....
Continue reading "Another "Bad Facts" Victory For The IRS In Estate of Erickson"
By: Ori Bash, ASAIn 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 winning the argument on most of...
By Lance S. Hall, ASA1Investors are still feeling the pain and panic of the dramatic stock market decline in the fall of 2008. In a mere 45 trading days from September 19 through November 20, 2008, the Dow Industrial Average...
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The IRS Continues to Attack Poorly Designed Family Limited Partnership: Estate of Concetta H. Rector
By: Jeff Bae & Craig StephansonValuation Services, Inc.IntroductionThe Internal Revenue Service (the "IRS") won another estate tax case dealing with a family limited partnership ("FLP"). In Estate of Concetta H. Rector (T.C. Memo. 2007-367), the Tax Court held that the...
By: Martin M. Shenkman, CPA, MBA, PFS, JD Introduction to Planning Through Economic Turmoil ◙ Introduction The markets are in turmoil. Daily Dow movements make Cedar Point roller coasters look tame. The remake of the movie "Fast and Furious" will...
By John Hempstead, ASA, CFAManaging Director, Hempstead & Co. Inc.Synopsis S corporations have become the corporate vehicle of choice for operating privately-held businesses. Because of their special tax attributes, however, they present certain challenges to appraisers attempting to value them...
Espen Robak Are estate planners shortchanging their clients by applying obsolete and inappropriate valuation rules that overvalue transferred stock options? Regardless of how you feel about the ability of older valuation methods to produce accurate estimates of...
Continue reading "A "Fair Market" Approach To Valuing Stock Options"