- 13 -
In this instance, both parties have stipulated that there
was no plan of liquidation. Accordingly, it is inapposite to
apply a discount for potential capital gain taxes when the
recognition event itself is purely speculative.
For the foregoing reasons, we will (1) grant respondent's
motion for summary judgment and (2) deny petitioner's motion for
summary judgment.
An appropriate order and
decision will be entered for
respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011