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Entertainment, Arts, and Sports Law Commons™
Open Access. Powered by Scholars. Published by Universities.®
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- Below market loans (1)
- Demand loans (1)
- Dickman v. Commissioner (1)
- Discounts (1)
- Elkins (1)
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- Estate tax (1)
- Federal gift tax (1)
- Fractional interests (1)
- Fractional interests in art (1)
- Income tax (1)
- LLC (1)
- Professional sports industry (1)
- Restricted agreements (1)
- Salary substitute (1)
- Section 2703 (1)
- Supreme Court (1)
- Tax avoidance (1)
- Tax neutrality (1)
- Transfer of wealth (1)
- U.S. Congress (1)
- Valuation (1)
Articles 1 - 2 of 2
Full-Text Articles in Entertainment, Arts, and Sports Law
Valuing Fractional Interests In Art For Estate Tax Purposes, Wendy G. Gerzog
Valuing Fractional Interests In Art For Estate Tax Purposes, Wendy G. Gerzog
All Faculty Scholarship
It is difficult to value fractional interests in art because there is virtually no market in those interests. Nevertheless, the Tax Court in Estate of Elkins valued the decedent’s fractional interests in multiple artworks, which the decedent and his children highly cherished. First, the court addressed the restricted agreements under section 2703 and then the court determined the value of decedent’s interests in the art.
Below Market Loans: From Abuse To Misuses – A Sports Illustration, Phillip J. Closius, Douglas K. Chapman
Below Market Loans: From Abuse To Misuses – A Sports Illustration, Phillip J. Closius, Douglas K. Chapman
All Faculty Scholarship
Below market loans have been traditionally used as substitutes for gifts, salaries, and dividends for the primary purpose of tax avoidance in the transfer of wealth. The Supreme Court's opinion in Dickman v. Commissioner subjected both demand and term loans in an intrafamilial setting to the federal gift tax. Congress, while subjecting all below market loans to either income or gift tax, applied different valuation formulas to term and demand loans and, in so doing, favored the use of demand loans as a salary substitute. This Article analyzes the current status of below market loans by examining their use in …