RERI Holdings I, LLC v. Comm'r
United States Tax Court
LLC1 contributed a successor member interest in a second LLC (LLC2) to University. R moves for partial summary judgment that (1) the actuarial tables under I.R.C. sec. 7520 do not apply to value the successor member interest and (2) TMP failed to substantiate the value of the successor member interest with a qualified appraisal as defined in sec. 1.170A-13(c)(3), Income Tax Regs.
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LLC1 contributed a successor member interest in a second LLC (LLC2) to University. R moves for partial summary judgment that (1) the actuarial tables under I.R.C. sec. 7520 do not apply to value the successor member interest and (2) TMP failed to substantiate the value of the successor member interest with a qualified appraisal as defined in sec. 1.170A-13(c)(3), Income Tax Regs. Held:Pierre v. Commissioner, 133 T.C. 24 (2009), followed; LLC2, a disregarded entity, is not disregarded in determining value of the successor member interest in LLC2 that LLC1 contributed to University. Held,…
1Opinion of the Court
RERI HOLDINGS I, LLC, HAROLD LEVINE, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
RERI Holdings I, LLC v. Comm'r
Docket No. 9324-08
United States Tax Court
143 T.C. 41; 2014 U.S. Tax Ct. LEXIS 34; 143 T.C. No. 3;
August 11, 2014, Filed
Reri Holdings I, LLC v. Comm'r, T.C. Memo 2014-99, 2014 Tax Ct. Memo LEXIS 100 (T.C., 2014)
An appropriate order will be issued denying respondent's motion for partial summary judgment.
LLC1 contributed a successor member interest in a second LLC (LLC2) to University. R moves for partial summary judgment that (1) the actuarial tables…
2Cases cited20 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Bond v. CommissionerUnited States Tax Court · 1993
- Commissioner v. SimmonsCourt of Appeals for the D.C. Circuit · 2011
- Ronald D. Smart, Doing Business as Paschall Electric v. International Brotherhood of Electrical Workers, Local 702Court of Appeals for the Seventh Circuit · 2003
- Weller v. CommissionerUnited States Tax Court · 1962
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