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Merger Is Indirect Gift In Cavallaro, Kerry A. Ryan
Merger Is Indirect Gift In Cavallaro, Kerry A. Ryan
All Faculty Scholarship
In Cavallaro v. Commissioner, the Tax Court held that a merger of two family-owned businesses resulted in a substantial taxable gift. The taxpayers avoided penalties by demonstrating that they relied in good faith on the mistaken advice of competent tax advisers.
Valuation Lessons From Estate Of Adell, Kerry A. Ryan
Valuation Lessons From Estate Of Adell, Kerry A. Ryan
All Faculty Scholarship
In Estate of Adell, the Tax Court determined that the correct value of a decedent’s interest in a closely held corporation was the figure reported on the original estate tax return. The court rejected alternative values as either using the incorrect valuation method or failing to account for the significant value of a key employee’s personal goodwill.