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UNITED STATES TAX COURT

Agency decision · Agency decision

Mitchell has been retained well over 100 times as an expert witness to - 24 [*24] determine valuations and appropriate discount rates for businesses, including in Hoffman v. Commissioner, T.C. … Pratt et al., supra, at 398-399. The Pratt treatise then lists three scenarios where a discount for lack of control would not apply (blocking power, swing vote, and takeover protection). Id.

UNITED STATES TAX COURT

Agency decision · Agency decision

She occasionally drives a car that is leased to -24[*24] the medical practice. The Francels are still married. … Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399, the requesting spouse must meet seven threshold requirements to be considered for relief under section 6015(f).

UNITED STATES TAX COURT

Agency decision · Agency decision

During the meeting on September 24, 1992, Ms. Hamilton advised Ms. … Commissioner, 47 T.C. 399, 410 (1967), affd. per curiam 398 F.2d 832 (6th Cir. 1968).

UNITED STATES TAX COURT

Agency decision · Agency decision

Mitchell has been retained well over 100 times as an expert witness to - 24 [*24] determine valuations and appropriate discount rates for businesses, including in Hoffman v. Commissioner, T.C. … Pratt et al., supra, at 398-399. The Pratt treatise then lists three scenarios where a discount for lack of control would not apply (blocking power, swing vote, and takeover protection). Id.

United States Tax Court

Agency decision · Agency decision

Proc. 2013-34, § 4.01, 2013-43 I.R.B. 397, 399–400, modifying and superseding Rev. Proc. 2003-61, 2003-2 C.B. 296. … R objects to the admissibility of certain letters in the Served 01/30/24 2 administrative record on the ground that they are inadmissible hearsay.

UNITED STATES TAX COURT

Agency decision · Agency decision

Decedent gave her children, collectively, a 24-percent interest in parcel 3. … Commissioner, supra at 24.

UNITED STATES TAX COURT

Agency decision · Agency decision

- 33 broaden the scope of the closing agreement beyond what the parties intended.28 S_e_e 17A C.J.S., Contracts, sec. 399 (2011); c£ 11 Williston on Contracts, sec. 32:10 (4th ed. 1999) ("Even absent … P'ship), 450 F.3d 24, 35 (1st Cir. 2006) ("Courts will not read language into a contract where it does not appear."); Estate of Magarian v.

UNITED STATES TAX COURT

Agency decision · Agency decision

Hall were aware that Ophthalmic Associates never - 24 [*24] paid Hall & Associates for any of the services allegedly performed.8 The testimony of Mr. … Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399-400. Respondent concedes that Mr. Hall satisfies the first six threshold conditions.

United States Tax Court

Agency decision · Agency decision

No. 13,164. 8 One more 1982 Treaty provision is important here, Article 24. … On May 24, 2022, the Court held a hearing on the Motions. Discussion I.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 69 T.C. 391, 399 (1977); Estate of Berkman v. Commissioner, T.C. Memo. 1979-46; sec. 20.2031-4, Estate Tax Regs. … - 24 the public market while the Clubside notes lacked a public market for sale. To account for this lack of marketability, Mr.

UNITED STATES TAX COURT

Agency decision · Agency decision

82/03/24 82/03/24 82/03/24 82/04/24 82/04/24 82/12/08 82/09/24 82/09/24 82/09/04 82/09/04 82/09/04 AUD. … 82/11/24 82/11/24 82/11/24 82/11/24 AUD.

UNITED STATES TAX COURT

Agency decision · Agency decision

82/03/24 82/03/24 82/03/24 82/04/24 82/04/24 82/12/08 82/09/24 82/09/24 82/09/04 82/09/04 82/09/04 AUD. … 82/11/24 82/11/24 82/11/24 82/11/24 AUD.

UNITED STATES TAX COURT

Agency decision · Agency decision

82/03/24 82/03/24 82/03/24 82/04/24 82/04/24 82/12/08 82/09/24 82/09/24 82/09/04 82/09/04 82/09/04 AUD. … 82/11/24 82/11/24 82/11/24 82/11/24 AUD.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 399 F.2d 603, 606 (9th Cir. 1968) (court found that corporate president was not underpaid in part because taxpayer's board did not state that some part of the payments were for his prior … Paying most of petitioner’s taxable income as compensation to its officers suggests that its - 24 distributions to Isidore and Steven Klein were in part disguised dividends.

United States Tax Court

Agency decision · Agency decision

Unless otherwise indicated, statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times, Served 05/21/24 2 [*2] and Rule references are to the Tax Court Rules … Commissioner, 248 F.2d 399, 411 (2d Cir. 1957) (Hand, J., dissenting), remanding T.C. Memo. 1956-137).

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7; Estate of Wallace v. Commissioner, 95 T.C. 525, 553-554 (1990), affd. 965 F.2d 1038 (11th Cir. 1992). … - 24 remanding T.C. Memo. 1980-282.

UNITED STATES TAX COURT

Agency decision · Agency decision

82/03/24 82/03/24 82/03/24 82/04/24 82/04/24 82/12/08 82/09/24 82/09/24 82/09/04 82/09/04 82/09/04 AUD. … 82/11/24 82/11/24 82/11/24 82/11/24 AUD.

UNITED STATES TAX COURT

Agency decision · Agency decision

- 24 [*24] Montgomery v. Commissioner, 65 T.C. 511, 520 (1975)), and is taxed at ordinary rates, Callahan v. Commissioner, T.C. Memo. 2013-131, at *29. … Memo. 1967-137, afR, 399 F.2d 326 (5th Cir. 1968); see a_lso Higgins v. Commissioner, 312 U.S. 212, 217 (1941).

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 248 F.2d 399, 411 (2d Cir. 1957)). Here, too, the transfers are "reminiscent" of those with which we have previously dealt. … Commissioner, 248 F.2d 399, 402 (2d Cir. 1957), remanding T.C. Memo. 1956-137 on another issue, affd. 262 F.2d 512 (2d Cir. 1959). In Gregory v.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 248 F.2d 399, 411 1957)). (2d Cir. Here, too, the transfers are "reminiscent" of those with which we have previously dealt. … Commissioner, 248 F.2d 399, (2d Cir. 1957), remanding T.C. Memo. 1956-137 on another issue, affd. 262 F.2d 512 (2d Cir. 1959). In Gregory v.