"Discussion Draft" Relating to Estate Valuation Freezes: Hearing Before the Committee on Ways and Means, House of Representatives, One Hundred First Congress, Second Session, April 24, 1990
U.S. Government Printing Office, 1990 - 424 lappuses
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abuses addition American amount apply appreciation approach appropriate assets Association avoid believe buy-sell agreements Chairman changes Chapter 14 child closely Code Committee common stock complex concern consideration considered continue corporation create death debt deemed gift determined discussion draft dividend effect election enterprise entity equity estate freeze estate tax example existing fact family business family members firm future gift tax give held income increase Internal Revenue Code issue lease legislation less limitations means million operating option owners ownership paid parent partnership pass percent period planning preferred stock present problem proposal purchase qualified fixed payments reason recapitalization receive repeal replacement represents respect result retained interest rules Section Service shares situation small business statement statute suggest taxpayers term transactions transfer tax transferor Treasury treated trust valuation
55. lappuse - Committee of the Section of Real Property, Probate and Trust Law of the American Bar Association WILLIAM P.
175. lappuse - Mr. Chairman and members of the Ways and Means Committee, I am a manufacturer from Missouri and Louisiana.
190. lappuse - Even if the decedent is not free to dispose of the underlying securities at other than the option or contract price, such price will be disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. (i) Stock sold "ex-dividend.
318. lappuse - Where, on the lapse of time, on the occurrence of an event or contingency, or on the failure of an event or contingency to occur...
1. lappuse - In view of the limited time available to hear witnesses, the Subcommittee may not be able to accommodate all requests to be heard. Those persons and organizations not scheduled...
24. lappuse - Section 1015 (relating 16 to basis of property acquired by gift) is amended by adding at 17 the end thereof the following new subsection: 18 "(f) SPECIAL VALUATION RULES TO APPLY.
96. lappuse - IRS will be barred from filing suit for unpaid taxes or for tax deficiencies due to higher government valuations of the gifts. If a taxpayer omits includable gifts amounting to more than 25 percent of the total amount of gifts stated in the return, the statute of limitations is extended to six years.
165. lappuse - ... disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. The Regulation permits Treasury to ignore options in buy-sells which have an estate planning motive rather than a business motive. For example, the...
125. lappuse - indefeasibly fixed" are drawn from a Model Disclaimer Act drafted by a Special Committee on Disclaimer Legislation of the Real Property, Probate and Trust Law Section of the American Bar Association. The Draft omits the words "both in quality and quantity" in the Model Disclaimer Act as unnecessary.