Page 64 - Business Valuation for Estates & Gift Taxes

Appendix C

Case Law

The purpose of this index is to provide a summary of cases that address, at least in part, specific subject
matter topics related to estate and gift tax and valuation issues. This appendix does not establish a com-
prehensive list of cases, nor is it designed to assess the relevance of a case to the facts and circumstances
of any case that may address similar facts and circumstances.

It is important for practitioners to note that the status of a case can change whenever a subsequent
case or judicial ruling is issued (for example, change from case law with no negative appellate his-
tory to a case that gets overruled by an appellate court). Therefore, practitioners (with assistance
from legal counsel) should perform their own due diligence on the status of any cases that follow
to determine if the case has been overruled or if relevant negative treatment exists.

Definition of FMV

 Estate of Bright v. United States, 658 F.2d 999 (5th Circuit, 1981).

Subsequent Events

 Ithaca Trust Co. v. United States, 279 U.S. 151 (1929).

 Campbell v. United States, 661 F. 2d 209 (Circuit Court of Claims, 1981).

 Estate of Gallo v. Commissioner, T.C. Memo 1985-363.

 Estate of Jung v. Commissioner, 101 T.C. 412 (1993).

 Scanlan v. Commissioner,116 F.3d 1476 (5th Circuit, 1997).

 Saltzman v. Commissioner, 131 F.3d 87 (2nd Circuit, 1997).

 Estate of Noble v. Commissioner, T.C. Memo 2005-2.

 The Ringgold Telephone Company v. Commissioner, T.C. Memo 2010-103.

Approaches to Value

 Estate of Hall v. Commissioner, 92 T.C. 312 (1989).

 Furman v. Commissioner, T.C. Memo 1998-157.

 Estate of Hendrickson v. Commissioner, T.C. Memo 1999-278.

 Estate of Dunn v. Commissioner, 301 F.3d 339 (5th Circuit 2002).

 Estate of Weinberg v. Commissioner, T.C. Memo 2000-51.

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