There’s something for nearly everyone in the U.S. Tax Court and the U.S. Court of Appeals for the Fifth Circuit opinions in Nelson v. Commissioner.1 Most notably, the cases highlight a dispute over the efficacy of defined value language in gift transfer documents. In this regard, Nelson joins a long list of such cases.2 From a valuation standpoint, the Tax Court dealt with a wide range of issues, including the valuation of holding companies, minority
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