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Valuation Discounts After Estate Of Nowell V. Commissioner: A Clear Formula For Reducing Estate Taxes, Russell Stanaland
Valuation Discounts After Estate Of Nowell V. Commissioner: A Clear Formula For Reducing Estate Taxes, Russell Stanaland
Golden Gate University Law Review
In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on property for purposes of calculating federal estate and gift tax liability. In its memorandum opinion, the court held that transferred property is valued without considering other similar property held by either the transferor or transferee for estate and gift tax purposes. The Nowell decision provided two important rules. First, a family may transfer property to various trusts and then claim that the total value of all trusts is worth less than the value of the underlying property because each trust owns only a partial …
Tax Law - In Re Kroy (Europe) Limited: Whether A Corporation May Amortize And Deduct Loan Fees Incurred In Financing A Stock Redemption, Robert G. Lorndale Jr.
Tax Law - In Re Kroy (Europe) Limited: Whether A Corporation May Amortize And Deduct Loan Fees Incurred In Financing A Stock Redemption, Robert G. Lorndale Jr.
Golden Gate University Law Review
In In re Kroy (Europe) Limited,l the Ninth Circuit held that a corporation could amortize and deduct fees which it incurred in borrowing funds used to redeem stock under §162(a) of the Internal Revenue Code. Section 162(a) allows a corporation to deduct ordinary and necessary business expenses. Kroy required the court to decide whether §162(k) of the Internal Revenue Code, an exception to §162(a), applied to these fees and would preclude their deduction. Section 162(k) disallows deduction of any expenses incurred "in connection with" a stock redemption. The Ninth Circuit determined that §162(k) did not apply to the fees because …
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Golden Gate University Law Review
No abstract provided.