 Service has concluded that, in the case of a corporation with a single class of stock, notwithstanding the family relationship of the donor, the donee, and other shareholders, the shares of other family members will not be aggregated with the transferred...  Financial Valuation Workbook - 205. lappuseautors: James R. Hitchner, Michael J. Mard - 2003 - 256 lapasIerobežota priekšskatīšana - Par šo grāmatu
 | Bruce L. Richman - 2002 - 306 lapas
...position taken in Rev. Rul. 81-253, and in light of the cases noted above, the Service has concluded that, in the case of a corporation with a single class of...should be valued as part of a controlling interest. In the present case, the minority interests transferred to A, B, C, D, and E should be valued for gift... | |
 | James R. Hitchner - 2003 - 1056 lapas
...Ruling 81-253 and issuing Revenue Ruling 93-12. Citing the aforementioned cases, the IRS concluded that: in the case of a corporation with a single class of...transferred shares should be valued as part of a controlling interest.44 Revenue Ruling 93-12 was a landmark ruling in that it opened door for use of FLPs and other... | |
 | Brent C. Shaffer - 2006 - 510 lapas
...Bright v. US, 658 F.2d 999 (5th Cir. 1981). In 1993, the IRS reconsidered its position, and stated that in the case of a corporation with a single class of...the family relationship of the donor, the donee, and the other shareholders, the shares of other family members would not be aggregated with the transferred... | |
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