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Valuation Pronouncements in ConnellyValuation Pronouncements in Connelly

Analyzing the underpinnings of the U.S. Supreme Court’s decision.

William H. Frazier, Managing Director, Valuation Services

January 23, 2025

13 Min Read
Supreme Court interior
CHBD/iStock/Getty Images Plus

The U.S. Supreme Court’s decision in Connelly v. United States1 has spawned a plethora of articles covering the case’s legal, tax, estate-planning and valuation aspects. 

It’s highly unusual for the Supreme Court to involve itself in tax matters, but it did so to resolve a split between the U.S. Court of Appeals for the Eleventh Circuit and the Eighth Circuit over the issue of whether life insurance proceeds that will be used to redeem a decedent’s shares must be included when calculating the value of those shares for purposes of the federal estate tax. In Estate of Blount v. Commissioner, the Eleventh Circuit opined that such cash didn’t add to a company’s value because it was offset by an equal corporate obligation.2 In Connelly, the Ei...

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About the Author

William H. Frazier

Managing Director, Valuation Services, Weaver

William H. Frazier, ASA, has over 40 years of experience in valuation, investment banking, mergers and acquisitions, and litigation advisory services. For the last 15 years, Will's career focus has included valuing family-owned businesses and holding entities, such as family limited partnerships. He has performed valuations for estate and gift taxation, fairness/solvency opinions, bankruptcy and reorganization, disputes related to business transactions and shareholder disputes, family law matters, purchase and sale advisement, employee stock ownership plans, equity compensation, financial reporting, and other litigation, tax and corporate matters. Additionally, Will has served as an expert witness and appraiser in several U.S. Tax Court cases.

Will is a senior member of the American Society of Appraisers (ASA) and former chair of the Government Relations Committee, former treasurer and secretary of the Business Valuations Committee (BVC) and head of ASA’s Task Reform Task Force. From 2008-2011, Will served on the Internal Revenue Service Advisory Council (IRSAC) where he was assigned to the Office of Professional Responsibility. He is currently a member of the Standards Sub-committee of the BVC and is the BVC’s liaison to the Government Relations Committee. He has authored numerous articles on the subject of business valuation for professional and business publications. Will is a frequent speaker and program presenter on the subject of estate and gift tax valuation.