Estate and gift tax valuations – 3 valuable lessons from the trenches

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Abstract: The IRS and taxpayers rarely see eye-to-eye when valuing businesses for estate and gift tax purposes. This article summarizes three recent developments from the U.S. Tax Court, a federal district court and the IRS Office of Chief Counsel that deal with the issue of fair market value in a federal estate and gift tax context. A sidebar explains why the IRS wouldn’t extend an estate’s deadline for claiming a refund under the financial disability exception. Cavallaro v. Commissioner, T.C. Memo. 2019-144 (Tax Ct. Oct. 29, 2019) Carter v. United States, No. 18-cv-01380-HNJ (N.D. Ala. Aug. 9, 2019)