T.C. Memo. 1999-254 UNITED STATES TAX COURT WALTER L. GROSS, JR., AND BARBARA H. GROSS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent CALVIN C. LINNEMANN AND PATRICIA G. LINNEMANN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4460-97, 4469-97. Filed July 29, 1999. ‚ Ps made gifts to their children of shares in S corporation, which, annually, distributed substantially all of its income. R determined gift tax deficiencies based on adjustments increasing the fair market value of the shares. Principal differences between the parties are (1) whether to “tax affect” corporation’s earnings in determining discounted cash- flow, (2) the discount for lack of marketability, and (3) the cost of equity. Held: Value of shares determined; marketability discount and cost of equity determined; tax affecting inappropriate under facts presented. James J. Ryan and Gerald J. Rapien, for petitioners. Robin Herrell and Matthew Fritz, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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