Tax Court holds that the discount for the tax on built-in gains should take into account both future appreciation on property and the present value discount for the projected capital gains tax
In Estate of Jensen v. Comm'r, T.C. Memo 2010-182 (Aug. 10, 2010), the question before the Tax Court was how to determine the discount for the built-in capital gains tax for property owned by a C corporation. Both the taxpayer and the Internal Revenue Service agreed that a discount
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