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Nelson: IRS Prevails in Defined Value Provision Case

By Steven M. Saraisky & David J. Choyne on July 16, 2020
Posted in Entity Taxation, Federal Gift, Estate and GST Tax, Income Tax

On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets.

The taxpayer’s primary business was in heavy equipment relating to the oil and gas industry.  The…

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