Notable 4th Quarter 2015 Cases, Part II of II Part II of this article highlights the remaining notable 4th Quarter 2015 U.S. Tax Court Cases that will be of interest to valuation practitioners and business advisors.  Estate of Purdue reminded us that taxpayers need to address 2036(a) concerns and establish a non-tax reason.  In addition, the case reminds us that gifting an equity or LLC interest may not qua ...

Notable 4th Quarter 2015 Cases, Part I of II Part I of this article highlights notable 4th Quarter 2015 U.S. Tax Court Cases that will be of interest to valuation practitioners and business advisors. Estate of Purdue reminds us that taxpayers need to address 2036(a) concerns and establish a non-tax reason. In addition, the case reminds us that gifting an equity or LLC interest may not qualify as a present i ...

T.C. Memo. 2015-249: A Checklist to Address 2036 Concerns The issue raised in Estate of Purdue v. Commissioner was whether the “decedent’s desire to have the marketable securities and the building interest held and managed as a family asset constituted a legitimate non-tax motive for the transfer of property to PFLLC.” ...