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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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	Home / Sitemap Sitemap About Us Clients History Professionals John E. Hempstead, ASA, CFA J. Mark Penny, ASA Daniel A. Lisman, CFA David N. Routzahn, Jr., ASA Michael D. Cunningham, ASA Andrew Scannell Fees Testimonials Valuation Services Estates Valuations Financial Reporting Valuations Accounting Related Valuations Business Combinations Valuations Goodwill Impairment Valuations Employee Stock Options Valuations IRS Code Section 409A Valuations Fresh Start Accounting Valuations Employee Stock Ownership Plans (ESOPS) Valuations Shareholder Transactions Valuations Mergers & Acquisitions Valuations Matrimonial Matters Valuations Bankruptcy and Reorganization Valuations Complex Capital Structures Valuations Life Science Companies Valuations Valuation of Personal Goodwill Fairness Opinions Economic Damages Analysis FAQs Contact Us Directions Join Mailing List Library Sitemap Proposal Request Newsletters Voting Control of LLC Shrinks Valuation Discount Discounted Stock Options are Deferred Compensation, Says Court Market Value Trumps Dodgy DCF in Verizon Case Incomplete Appraisal Report Dooms Charitable Deduction Marketability Discount Upheld in New York Fair Value Opinion Wandry Appeal Withdrawn by IRS Orchard Enterprises Case Provides Some Explicit Valuation Guidance Court Rules Out Cost Method For Valuing Technology Delaware Appraisal Finding is $6 Million Lower than the Merger Price The Wandry Taxpayers Found The Formula Courts Allow Reallocation of Gifted Shares Book Value was 2% of Fair Market Value in NJ Buyout Case Estate Tax Underpayment Penalty Waived in Giustina Case Estate of Gallagher is a Valuation Tutorial Delaware Chancery Court Ignores “Outlier” DCF Valuation Extraordinary Estate Planning Opportunities are Created by New Tax Act DCF Valuation Scuttled by Unsound Underlying Projection The Best Valuation Approach is Not Always DCF Tax Court Recognizes Full Valuation Discount for Capital Gains Family LLC Half-Interest Wins a 35% Valuation Discount Chancery Court Clears Up Two Valuation Issues IRS Valuation Win Upheld in Holman Appeal FLP Discounts Save Murphy Family $41 Million Middle Market Deal Valuations Held Steady in 2009 DCF Valuation Trumps Market Price in American Home Mortgage Case Silicon Valley Venture Financings – Up Rounds Rallying Tax Court Splits on FLP Discounts Silicon Valley Venture Financing – Down Rounds Predominate Life Science Venture Financing – Down Rounds Are Up Goodwill Impairments Up Dramatically Goodwill Accounts for 47% of Average M & A Allocation Middle Market Deal Valuations Held Steady in Q4 2008 Daubert Challenges of Financial Experts Up Sharply Built-In Gains Tax Measured Fully in Litchfield Case House Proposal Could Spell the End of Minority Valuation Discounts Divore Valuation Shaped by Estate Tax Valuation Principles Sequoia Slideshow is the Talk of the Life Sciences Venture Summit Is the Holman FLP Valuation Decision a Win for the IRS? Multi-Level Discounts Allowed in Gift Tax Valuation New Fairness Opinion Ruling Addresses Conflicts Daubert Challenges of Financial Experts up by 89% Jelke Decision Sets New Valuation Standard Estate of Jelke Reversal is a Major Win for Taxpayers IRS Extends §409A Compliance Deadline Revised Private Equity Valuation Guidelines Issued §409A Option Valuation Regulations Issued FLP Discount Nixed by Pennsylvania Court Discounted Stock Option Compliance Deadline Approaches IRS Issues Discount Guidance for Family Limited Partnerships Chancery Court Uses FAMA-French Model to Value Bank Market-Based Stock Option Valuations Receive SEC Blessing Tax Court Uses Dribble-Out Method to Value Restricted Stock Hempstead & Co. Offers Valuation CPE Course to CPAs IRS Defines Qualified Appraisal and Qualified Appraiser S-Corp Valuations Revisited by Tax Court FASB Issues New Statement on Fair Value IRS Redefines Gross Valuation Misstatement Taxpayers’ Appraiser Upheld by Fifth Circuit Appraisal Blunders Sink IRS in Major Estate Tax Case Taxpayer Wins 60% Gift Tax Valuation Discount Tax Court Says OK to 50% Valuation Discount Sub-S Corp Valuation Issues Addressed in Delaware Chancery Decision IRS Code §409A Necessitates Case in Setting Stock Option Exercise Prices Taxpayers’s LLC Valuation Produces Refund in Anderson Estate Tax Case

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