William Cavallaro, Donor v. Commissioner

T.C. Memo. 2019-144

UNITED STATES TAX COURT WILLIAM CAVALLARO, DONOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* PATRICIA A. CAVALLARO, DONOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3300-11, 3354-11. Filed October 24, 2019. Ps owned KT Corp., and their three sons owned CS Corp. Ps and their sons merged the two in 1995, and CS Corp. was the surviving entity. In valuing the two companies for purposes of the merger, they incorrectly assumed that CS Corp. owned intangibles that instead KT Corp. owned. Ps therefore accepted a dispropor- tionately low…