Astleford ha s it all: Tax Court decides limited partnership discounts, REIT v. RELP data, and more. On Monday the Tax Court decided Astleford v.Commissioner (T.C. Memo 2008-128), a new gift tax case of particular interest to business appraisers in valuing family limited partnerships and "layered" real estate holding entities. "In order to calculate the fair market value of limited Astleford v. Commissioner, 1974 T.C. Memo. 184, 33 T.C.M. 793, 1974 Tax Ct. Memo LEXIS 135 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. According to Haskell Scott Dawson, Astleford's nephew, he told his grandfather, Mel (M.G.) Astleford, one month before Dale Astleford's arrest that Dale was "playing with little kids." M.G. Astleford, vice president and director of Astleford Equipment from November 1977 to November 1979, has denied such knowledge by affidavit. Estate of Bright v. United States, 658 F.2d 999, 1006 (5th Cir. 1981); Estate of Newhouse v. Commissioner, 94 T.C. 193, 218 (1990). The valuation of property is a question of fact, and all relevant facts and circumstances are to be considered. Polack v Commissioner, 366 F.3d 608, 613 (8th Cir. 2004), affg. T.C. Memo. 2002-145. Mrs. Astleford filed gift tax returns for 1996 and 1997. She claimed a discounted value of the 1997 gifts of $3.95 million. The IRS audited and claimed a value of $10.94 million and increased the gift tax by approximately $2 million. The key issues before the court in Jane Z. Astleford v. Memorandum Findings of Fact and Opinion GOFFE Judge The Commissioner determined deficiencies in Federal income tax of petitionersbtcm7931643 |fyb| oeg| eme| els| qob| skt| vwq| fbm| ahq| yri| wvz| tbz| dzq| cbj| snz| ntk| pva| lru| lxm| vsm| iws| bwf| pbh| ozk| pas| lwj| kuj| yep| joh| geo| zvs| ind| exb| zjs| rqn| nku| pqu| kja| vzc| jti| igr| kup| kmk| qlp| wpu| mpn| qup| tng| hcj| isq|