Tax Law Update

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 regulations (133 TC No. 2 (Aug. 24, 2009)). However, other issues that the court had bifurcated were left undecided. The Tax Court

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 transacti

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