Keeping Up with the Joneses: A Fresh Perspective on Tax-Affecting

Abstract

This article examines Estate of Jones v. Commissioner, provides a brief historical context of the opinions that consider tax-affecting in prior Tax Court and Federal Circuit Court opinions, reviews current trends in determining FMV for transfer tax purposes, and offers several key observations, specifically in light of the current economic climate with COVID-19. As this article will discuss, valuation professionals may want to “keep up with the Joneses” by carefully reviewing whether it makes sense to provide similar supporting evidence, as provided in Jones, when appraising a closely-held business with similar characteristics for transfer tax purposes.