McCord v. Comm'r
United States Tax Court
Ps, their children, and their children's partnership formed a family limited partnership (PT). In 1996, Ps assigned interests in PT to several assignees pursuant to an agreement that contains a formula clause.
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Ps, their children, and their children's partnership formed a family limited partnership (PT). In 1996, Ps assigned interests in PT to several assignees pursuant to an agreement that contains a formula clause. The formula clause provides that (1) Ps' children, trusts for their benefit, and S, a charitable organization, are to receive interests having an aggregate fair market value of a set dollar amount, and (2) C, another charitable organization, is to receive any remaining portion of the assigned interests. Ps' children agreed to pay all transfer taxes resulting from the transaction,…
1Opinion of the Court
TABLE OF CONTENTS
FINDINGS OF FACT 361
rypTNnrvNr 367
367 I. Introduction .
368 II. Relevant Statutory Provisions .
369 III. Arguments of the Parties .
370 IV. Extent of the Rights Assigned.
373 V. Fair Market Value of the Gifted Interest .
373 A. Introduction .
373 1. General Principles .
374 2. Expert Opinions .
374 a. In General .
374 b. Petitioners’ Expert .
375 c. Respondent’s Expert .
375 B. Value of Underlying Assets .
376 C. Minority Interest (Lack of Control) Discount
376 1. Introduction .
376 2. Discount Factors by Asset Class .
376 a. Equity Portfolio.
377 (1) Measurement Date ..
377 (2) Sample of…
2Cases cited25 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. CraftSupreme Court of the United States · 2002
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
20 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Succession of McCord v. CommissionerCourt of Appeals for the Fifth Circuit · 2006
- Peracchio v. Comm'rUnited States Tax Court · 2003
- Hendrix v. Comm'rUnited States Tax Court · 2011
- Lappo v. Comm'rUnited States Tax Court · 2003
- Estate of Green v. Comm'rUnited States Tax Court · 2003
19 more not listed; retrieve them via the Exa API.