American Bar Association
 
Tax Litigation and Controversy  

Tax Litigation and Controversy

 

SHURTZ: Estate of Shurtz v. Comm'r: Taxpayer victory on § 2036 issue
SHURTZ: Steve Akers' commentary on Estate of Shurtz v. Comm'r
PRICE: Price v. Comm'r: Tax Court denies annual exclusion gifts for gifts of partnership interests
PRICE: Steve Akers' Commentary on Price v. Comm'r
PETTER: Estate of Petter v. Comm'r: Tax Court rules in favor of defined value formula clause and holds that the clause does not violate public policy; taxpayer victory
PETTER: Steve Akers' commentary on Estate of Petter v. Comm'r
CHRISTIANSEN: Estate of Christiansen v. Comm'r: Tax Court approves formula disclaimer that operates much like a defined value transfer clause
CHRISTIANSEN: Estate of Christiansen v. Comm'r: 8th Circuit affirms Tax Court; taxpayer victory on defined value formula clase and public policy
CHRISTIANSEN: Steve Akers' commentary on Estate of Christiansen v. Comm'r
BLACK: Estate of Black v. Comm'r: Taxpayer victory on § 2036 issue; IRS victory on Graegin loan
2053 REGS: Steve Akers' commentary on final regulations under section 2053
MURPHY: Estate of Murphy v. United States: Taxpayer victory on section 2036 and valuation
MURPHY: Steve Akers' commentary on Estate of Murphy: total taxpayer victory in FLP case involving § 2036, Rule 144/blockage discounts, FLP discounts, and Graegin loan
ASTLEFORD: Astleford v. Comm'r
KELLEY: Estate of Kelley v. Comm'r: Tax Court finds estate tax 32.2% discount for FLP owning only cash and CDs
BAIRD: Estate of Baird v. Comm'r : Tax Court tags IRS with fees and costs in undivided interest discount case
BIGELOW: Bigelow v. Comm'r: Ninth Circuit view of applying § 2036 to family limited partnerships
SCHUTT: Estate of Schutt v. Comm'r: Tax Court applies bona fide sale exception to §§ 2036(a) and 2038
ABRAHAM: Estate of Abraham v. Comm'r
BONGARD: Estate of Bongard v. Comm'r
BONGARD: Estate of Bongard v. Comm'r: Tax Court § 2036 FLP/LLC case
BONGARD: Steve Akers' commentary on Estate of Bongard v. Comm'r
HACKL: Hackl v. Comm'r: Seventh Circuit rules on gift of present interest
KORBY: Estate of Korby v. Comm'r: Eighth Circuit upholds applying § 2036 to FLP assets
KORBY: Steve Akers' summary on Estate of Korby v. Comm'r (8th Cir.)
HILLGREN: Estate of Hillgren v. Comm'r: § 2036(a)(1) Case
HOLMAN: Holman v. Comm'r: Tax Court rejects "integrated transaction theory" for gift made 6 days after FLP formed
McCORD APPEAL: McCord v. Comm'r: Fifth Circuit respects defined value clause in blockbuster case of 2006
McCORD: McCord v. Comm'r: Fifth Circuit reverses Tax Court, respecting defined value transfer clause
MIROWSKI: Estate of Mirowski v. Comm'r
RECTOR: Estate of Rector v. Comm'r: Tax Court rules for IRS in § 2036 case
RECTOR: Steve Akers' commentary on Estate of Rector v. Comm'r
ERICKSON: Estate of Erickson v. Comm'r: Tax Court rules for IRS in § 2036 case where partnership funds were used to pay decedent's estate taxes
ERICKSON: Steve Akers' commentary on Estate of Erickson v. Comm'r
SENDA: Senda v. Comm'r: Tax Court rules on indirect gift
STONE: Estate of Stone v. Comm'r
FLP OVERVIEW: John Porter: Limited Partnerships and Valuation: A Review After 20 Years of Battle (Sept. 15, 2008)


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