Business Related Issues
Bad Jumbo

Smaldino v. Commissioner
T.C. Memo. 2021-127

On November 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smaldino v. Commissioner (T.C. Memo. 2021-127). The primary issues presented in Smaldino were whether (1) the proper characterization for gift tax purposes of petitioner’s purported transfer of LLC class B member interests to Mrs. Smaldino followed by her purported retransfer of these same interests to the Dynasty Trust and (2) the fair market value of the LLC class B member

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Scott St. Amand March 31, 2022
Business Related Issues
Discounts for Lack of Control and Marketability

Estate of Warne v. Commissioner
T.C. Memo. 2021-17

On February 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Warne v. Commissioner (T.C. Memo. 2021-17). The primary issue presented in Estate of Warne v. Commissioner was whether the IRS erred in increasing the value of the estate and the LLCs and by denying a giant charitable deduction ($25 million).  Specifically, the issues in Estate of Warne v. Commissioner concerned valuation of certain family LLCs, discounts for lack

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Scott St. Amand February 18, 2021
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Smaldino v. Commissioner
T.C. Memo. 2021-127

On November 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smaldino v. Commissioner (T.C. Memo. 2021-127). The primary issues presented in Smaldino were whether (1) the proper characterization for gift tax purposes of petitioner’s purported transfer of LLC class B member interests to Mrs. Smaldino

Read More »
Scott St. Amand March 31, 2022

Estate of Warne v. Commissioner
T.C. Memo. 2021-17

On February 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Warne v. Commissioner (T.C. Memo. 2021-17). The primary issue presented in Estate of Warne v. Commissioner was whether the IRS erred in increasing the value of the estate and the LLCs and by

Read More »
Scott St. Amand February 18, 2021