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In the case of Smaldino v. Comr., T.C. Memo. 2021-127, the business appraiser separately valued the LLC units that each separate spouse had donated.
In the case of Smaldino v. Comr., T.C. Memo. 2021-127, the effect of the decision affected Mrs. Smaldino’s gift tax applicable exclusion amount.
In the case of Connelly v. United States, 4:19-cv-01410-SRC (E.D. Mo. Sep. 21, 2021), the district court followed the Blount and Cartright decisions out of the Ninth and Eleventh Circuit Courts of Appeal in holding that the value of the subject company at the enterprise level of value included all of the life insurance on the decedent’s life.
In the case of Connelly v. United States, 4:19-cv-01410-SRC (E.D. Mo. Sep. 21, 2021), excluding life insurance from the enterprise value of the subject company is more consistent with the intentions of the owners.
In the case of Nelson v. Comr., T.C. Memo 2020-81, aff’d No. 20-61068 (5th Cir. Nov. 3, 2021), the taxpayers lost because they failed to include the ten most important words in defined value gifts: as finally determined for federal estate and gift tax purposes.