Income taxes and stock values

Article Abstract:

The author discusses the valuation of stock for transfer tax purposes with a focus on the role played by corporate income taxes. The issue of earnings based valuation is included in this discussion which includes the Tax Court memorandum 2000 and 1999 cases of Estate of Dunn and Gross.

Cases, Securities, Corporate income taxes, Transfer taxes

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For Tax Court valuation decisions, a string of reversals

Article Abstract:

The US Tax Court was reversed by appellate courts six times in 1998 on the issue of valuation of business interests. Most of these reversals may have been inappropriately based upon questions of fact. Appellate courts should be more deferential to the Tax Court's valuation determinations because the Tax Court has particular expertise in valuation. Additionally, the uncertainty created by these reversals discourages taxpayer-IRS settlements.

Small Business, Standards, Analysis, Evaluation, Tax appeals, Judicial review, Law and fact

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Do minority shareholders matter? Mixed signals from the Tax Court

Article Abstract:

The author discusses the relevance of minority stockholders in the valuation of stock included in decedents' estates. Tax Court cases are included in the discussion.

Decedents' estates, Family-owned business enterprises, Family-owned businesses, Stock rights, Stockholders' preemptive rights

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