Respondent determined a $333,244.59 deficiency in the Federal estate tax of the Estate of Marie J. Jensen (decedent). The issue for decision is the amount of the discount for built-in long-term capital gains tax (LTCG tax) that is allowable in computing the fair market value of the estate’s intere...   MORE>>

This case involves the damages claims of Plaintiffs Consolidated Edison Company of New York, Inc. (“Con Ed”) and Entergy Nuclear Indian Point 2, LLC (“Entergy”) caused by the failure of the Department of Energy (“DOE”) to collect and dispose of spent nuclear fuel. Under the terms of DOE�...   MORE>>

This litigation stems from the lack of performance by the Department of Energy (“DOE”) of its statutory and contractual obligations to collect spent nuclear fuel from the Pilgrim nuclear power station in Plymouth, Massachusetts. In separate suits, both the buyer and the seller of the Pilgrim sta...   MORE>>

Respondent determined a $1,130,216 deficiency for 2000 and a $24,969 deficiency for 2001 in petitioner’s Federal gift tax and generation-skipping transfer (GST) tax.

The Court bifurcated the issues in this case, and we addressed a legal issue of first impression in an earlier Court-reviewed opi...   MORE>>

Respondent determined a deficiency of $925,260 in petitioner’s Federal income tax for tax year 2000 and a penalty under section 6662(a) of $185,052. The issues to be decided are: (1) For purposes of determining built-in gain under section 1374, whether the fair market value of a partnership intere...   MORE>>

Thomas H. Holman, Jr. and Kim D.L. Holman (the “donors”) created a limited partnership, funded it with common stock of Dell, Inc., and gifted limited partnership shares to their children. In a gift-tax return, the donors asserted lack-of-marketability and minority-interest discounts to claim a v...   MORE>>

On this appeal from the tax court, we must decide whether, under the tax regulations in effect during tax years 1997, 1998 and 1999, related companies engaged in a joint venture to develop intangible property must include the value of certain stock option compensation one participant gives to its em...   MORE>>

The Commissioner of Internal Revenue (“the IRS”) disallowed a “qualified family-owned business interest” estate tax deduction to Mary Artall’s estate. Upon petition, the Tax Court found for the IRS. We affirm.

This case turns on the interpretation of § 2057 of the Internal Revenue Code...   MORE>>

This case was tried to a jury beginning on February 10, 2009. Against defendant Ratier-Figeac S.A.S. (“Ratier”), the jury considered plaintiff’s claims for breach of the duty of good faith and fair dealing, fraud, and misappropriation of trade secrets. Against Hamilton, the jury considered pla...   MORE>>

First Hartford Corporation (FHC) managed real estate development properties consisting of mostly neighborhood or strip malls. Through its subsidiaries, it held and managed most of its property for income potential but also purchased and developed property for resale. Although FHC was a publicly he...   MORE>>