Tax Court collapses gift and sale transaction but upholds discount — In 2009, the Tax Court held that the single member limited liability company (LLC) Suzanne J. Pierre formed as a part of her estate plan shouldn't be disregarded for gift tax valuation purposes under the “check-the-box” regulations (133 TC No. 2 (Aug. 24, 2009)). However, other issues that the court had bifurcated were left undecided. The Tax Court has now addressed the outstanding issues of whether the step
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