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- In Warne, Court Allows Discount for Real Estate Controlling . . . - Stout
In the February 18, 2021, decision in the Estate of Warne v Commissioner, the U S Tax Court (T C Memo 2021-17) allowed discounts for lack of control and lack of marketability for majority controlling interests in five real estate holding entities, preferring the approach and analyses presented by the Estate’s expert in rendering its opinion
- Estate of Warne v. Commissioner - Briefly Taxing
Specifically, the issues in Estate of Warne v Commissioner concerned valuation of certain family LLCs, discounts for lack of marketability for interests in such LLCs, and whether minority interest discounts applied to the charitable contribution deductions
- Tax Court Allows for ‘Slight’ Discount for Lack of Control for Majority . . .
Companies Estate of Warne v Commissioner In a gift and estate tax dispute, the estate and Internal Revenue Service agreed to apply discounts for lack of control and marketability to the majority interests in several real estate holding companies The U S Tax Court noted that, in prior decisions, the court found no discount for lack […]
- Valuation Insights From Warne v. Commissioner
In the Estate of Miriam Warne (“Estate”), T C Memo 2021-17 Tax Court Judge Buch was asked to determine the estate and gift tax values of certain real estate holding limited liability companies (“LLCs”) that held income-producing ground leases in several properties located in California
- Minority interest discounts apply to charitable bequests
At the time of her death, the trust was the majority interest holder of five LLCs: WRW Properties, VJK Properties, Warne Ranch, Warne Investments, and Royal Gardens WRW was a real estate holding company with leased-fee interests in two properties VJK was a real estate holding company with a leased-fee interest in another property
- Steve Akers + Ron Aucutt: Estate of Warne v. Commissioner, T. C. Memo . . .
The summary is as follows: Estate of Warne v Commissioner, T C Memo 2021-17 values majority interests in LLCs owning real estate and addresses reductions of the available estate tax charitable deduction for interests…
- Warne Case gives Insight on Valuation and Gifting - ESA Law
The operating agreement for each of the Five LLCs contained common provisions regarding the transfer of interests, restrictions on dissolving an interest, and others which vested considerable power in the majority interest holder In 1981, the Warnes created the Warne Family Trust (“Family Trust”)
- Tax Court allows for ‘slight’ discount for lack of control for majority . . .
In a gift and estate tax dispute, the estate and Internal Revenue Service agreed to apply discounts for lack of control and marketability to the majority interests in a number of real estate holding companies The U S Tax Court noted that, in prior decisions, the court found no discount for lack of control applied However, given the parties’ agreement, here the court said it would apply a
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