Keeping Up with the Joneses: A Fresh Perspective on Tax-Affecting
Date
2021
Authors
Journal Title
Journal ISSN
Volume Title
Publisher
Estate Planning and Community Property Law Journal
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.
Description
Keywords
Estate planning, Closely-held business, Transfer tax, Jones v. Commissioner, IRS valuation challenge, Tax court, Valuation, Kress v. United States, Cecil v. Commissioner, Gross v. Commissioner, Tax Cuts and Jobs Act of 2017
Citation
13 Est. Plan. & Cmty. Prop. L. J. 417