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Jelke Reversal
Business Valuation Resources, Jan 2008, Pages: 72
Recently the 11th Circuit Court of Appeals approved a “dollar-for-dollar” reduction for the entire built-in capital gains tax liability of a minority interest in a closely held corporation, overruling the Tax Court’s prior allowance of only a partial discount. In Estate of Jelke v. Comm’r (November 15, 2007) the Court reviewed the historical evolution of corporate tax reform and related case law—including the 5th Circuit’s decision in Estate of Dunn (2002)—to come to an accord “with the simple yet logical analysis of the tax valuation issues set forth [in Dunn], providing practical certainty to tax practitioners, appraisers and financial planners alike.” Will Frazier of Howard Frazier Barker Elliott, Inc , John Porter of Baker Botts in Houston, and Michael Paschall of Banister Financial, Inc. share their expert analysis on the Jelke reversal. Learn how this case evolved and the key arguments influencing the court’s decision; Find out the experts’ opinion on the stability of the ruling; and hear a discussion on the implications of this decision on the BV profession and how it will affect your practice.
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