Estate of Michael J. Jackson v. Commissioner – Key Takeaways

It is imperative for estate planners to engage valuation analysts that perform the proper procedures and follow best practices when performing valuations for gift and estate planning purposes. It is necessary to have a well-supported valuation because these reports are scrutinized by the IRS and may end up going to court. The recent decision by the U.S. Tax Court in Estate of Michael J. Jackson v. Commissioner provides several lessons and reminders for valuation analysts, and those that engage valuation analysts, to keep in mind when performing valuations for gift and estate planning purposes.

Patel v. Patel

In this case, the parties raised the matter to appeals for two issues: 1) whether the trial court erred in awarding Wife alimony in futuro of $7,500 per month, and 2) whether Wife is entitled to attorney’s fees.

A “Grievous” Valuation Error: Tax Court Protects Boundaries of Fair Market Value in Grieve Decision

All fair market determinations involve assumptions regarding how buyers and sellers would behave in a transaction involving the subject asset. In a recent Tax Court case, the IRS appraiser applied a novel valuation rationale predicated on transactions that would occur involving assets other than the subject interests being valued. In its ruling, the Court concluded that this approach transgressed the boundaries of what may be assumed in a valuation.

Tennessee Case Review

Tarver v. Tarver- Appeal from the Circuit Court for Shelby County January 16, 2019

New York’s Largest Corporate Dissolution Case: AriZona Iced Tea

After several years of litigation involving a number of hearings and trials on various issues, a trial to conclude the collective fair value of a group of related companies known as the AriZona Entities occurred. This article presents an in-depth discussion of the case and the valuation issues present.

Richmond v. Commissioner

In this article, we discuss the case of Richmond v. Commissioner in which the valuation of the Estate of Helen Richmond was questioned.

Janda v. Commissioner: The QMDM Appears in Tax Court Again

The Tax Court Memorandum demonstrated that the Court thoroughly studied and it appears well understood the QMDM. While the Court did not accept the expert’s 65.77% discount, the Court criticized the assumptions used, not the QMDM.

Weinberg et al. v. Commissioner

Based on our review of the case and Dr. Kursh’s report, it appears that Dr. Kursh used information that was factually based and within the range of reasonable comparisons with market data in his application of the QMDM. It is unfortunate, but the Court was apparently not convinced of the reasonableness of Dr. Kursh’s assumptions and their consistency with “hard data” that was in his report and otherwise readily available.

The Estate of Verna Mae Crosby

A 1997 case illustrates the complexities that can evolve in the valuation of debt securities and the weight the Tax Court applies to an appraiser’s effort to obtain and verify information on a particular interest to be valued.

Wandry v. Commissioner

The Wandry case is a boon not only for business owners but also wealthy families with family limited partnerships or entities holding publicly traded stocks.

Estate of Stone: Victory for Family Limited Partnerships

The Family Limited Partnership (“FLP”) has been a common estate planning technique for the nation’s wealthy. For years it allowed families to avoid some tax liability when transferring assets to heirs by first placing those assets in a FLP.