Wills, Trusts & Estates Prof Blog

Editor: Gerry W. Beyer
Texas Tech Univ. School of Law

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Wednesday, August 13, 2014

Tax Case Became Battle Between the Estate and Itself

Money ScaleAs I have previously discussed, the estate of Franklin Adell, who died August 2006, was recently in tax court regarding notices of deficiency from the IRS. The Adell state was in Tax Court again, for the third time. This time the estate was in court regarding the valuation of STN.Com, a company that was controlled by Adell, then by his son Kevin after Adell’s death.

In Estate of Franklin Z. Adell v. Commissioner, the valuation of STN was more than the common situation of the estate valuing the asset at less than the IRS, but rather the estate had valued the asset at significantly different amounts. The company was first valued at $9.3 million on a Form 706, and then at trial at $4.3 million. The Tax Court did not find convincing evidence that the first valuation was an error and valued the company according to the first Form 706 admission.

See Espen Robak, Valuation Lessons from Estate of Adell, Wealth Management, Aug. 11, 2014.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

http://lawprofessors.typepad.com/trusts_estates_prof/2014/08/tax-case-became-a-battle-between-the-estate-and-itself.html

Estate Planning - Generally, Estate Tax, New Cases | Permalink

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