January 31, 2024

In the companion article to this one, “Key Tax Court Cases on Valuation of Pass-Through Entities: The Early Years,” p. 44, Timothy J. Meinhart gives an overview of cases from 1999 to 2019.1 I’ll focus on the cases decided from 2020 to 2023: Grieve v. Commissioner,2 Lucero v. United States,3 Warne v. Comm’r,4 Michael Jackson v. Comm’r,5 Nelson v. Comm’r6 and Cecil v. Comm’r,7 which all relate to tax-affecting and other issues associated with pass-through entities.
Grieve
In Grieve,8 the court had to determine the value of a 99.8% nonvoting interest in a grantor retained annuity trust and an irrevocable trust. Each of the two trusts were made up of 99.8% nonvoting interests and 0.2% voting interests in a limited liability company (LLC) cal...
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