The Feds Carry a Bigger StickThe Feds Carry a Bigger Stick
Only a few valuation-related cases were decided in 2007, but their negative impact on taxpayers was enormous. For appraisers and advisors, only a few rules were adopted last year but their whole world got harsh. Yet not all of the valuations news in 2007 is bad: The federal courts showed a healthy appreciation for the valuation of restricted, non-marketable stock and the built-in gains tax liability
Radd L. Riebe
Only a few valuation-related cases were decided in 2007, but their negative impact on taxpayers was enormous. For appraisers and advisors, only a few rules were adopted last year — but their whole world got harsh. Yet not all of the valuations news in 2007 is bad: The federal courts showed a healthy appreciation for the valuation of restricted, non-marketable stock and the built-in gains tax liability of an asset-holding C corporation.
The Tax Court's valuations cases focused on Internal Revenue Code Section 20361 inclusion in estates of decedents who established faulty family limited partnerships (FLPs). In these cases, taxpayers generally made some common mistakes involving decedents impoverished after putting their assets ...
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