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Voting Control of LLC Shrinks Valuation Discount

May 2013 | Issue 66 The primary issue in Estate of Koons v. Commissioner (T.C. Memo. 2013-94, April 8, 2013) was the determination of the fair market value, at the date of his death, of John Koons’ 50.5% interest (47% voting) in a company called Central Investment LLC.  Central had been established as an entity [...] More...

Discounted Stock Options are Deferred Compensation, Says Court

April 2013 | Issue 65 Introduction A discounted stock option is one whose exercise price, at time of grant, is lower than the then fair market value of the underlying stock.  The IRS has maintained that discounted stock options will be treated as deferred compensation, pursuant to Section 409A of the Internal Revenue Code.  Such [...] More...

Market Value Trumps Dodgy DCF in Verizon Case

March 2013 | Issue 64 Introduction On November 17, 2006, Verizon Communications spun off its Yellow Pages subsidiary, Idearc, Inc.  The debt load assumed by Idearc in the transaction ultimately proved to be too heavy a burden and, 28 months later, the company went into bankruptcy. U S Bank NA, as Trustee of the Idearc [...] More...

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