Publications
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THE IMPACT OF COVID-19 ON BUSINESS VALUES & REAL ESTATE
- March 30, 2020
- Category: Commercial & Shareholder Litigation, Corporate Advisory & Tax Compliance, Estate & Gift Valuation, Healthcare Valuation & Advisory, Matrimonial Valuation & Litigation Support, Uncategorized
By David Rudman, CPA/ABV, CVA With the current Coronavirus outbreak worldwide, COVID-19 has caused many businesses, securities, and real estate investments to decline in value. While the underlying forces causing these declines in value have been very painful to endure, significant opportunities exist for those interested in transferring wealth, or for estates needing to
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Grieve v. Commissioner: A Failed Attempt by the IRS to Reduce Valuation Discounts on Non-Voting Interests
- March 27, 2020
- Category: Corporate Advisory & Tax Compliance, Estate & Gift Valuation
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. Synopsis: In Grieve v. Commissioner (T.C. Memo. 2020-28) published March 2, 2020, the IRS found a deficiency in the petitioner’s 2013 Federal gift tax and applied an unusual valuation theory in an attempt to minimize valuation discounts where the entity’s ownership was split between voting and
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Case Highlights: Estate of Aaron U. Jones v. Commissioner, T.C. Memo. 2019-101
- September 6, 2019
- Category: Uncategorized
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. Synopsis In May 2009, Aaron Jones gifted his interests in an S corporation and limited partnership that together owned a lumber and timber business to his three daughters and to his family trusts for their benefit. In his gift tax return, he reported the gifts
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Kress v. United States: US District Court Approves of Tax Affecting S-Corporation with No S-Corp Premium
- April 17, 2019
- Category: Estate & Gift Valuation
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. On March 25, 2019, the US District Court – Eastern District of Wisconsin issued a decision in Kress v. United States[1] where Chief Judge William C. Griesbach relied heavily on the taxpayer’s expert in valuing non-controlling interests in an operating S-Corporation called Green Bay Packaging,
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AICPA Adequate Disclosure Reference for 2016 Gifts Made After Issuance of the Proposed Section 2704 Regulations
- January 26, 2017
- Category: Uncategorized
AICPA Suggested Disclosure Statement For 2016 Gift Tax Returns Reporting Transfers of Interests in Family Controlled Entities, Include Adequate Disclosure Reference for the Section 2704 Proposed Regulations Under the adequate disclosure rules, if a position taken on a gift tax return is contrary to a proposed regulation, it must be disclosed in order for the
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Common Errors in the Valuation of Carried Interests and Fund Management Structures
- December 2, 2016
- Category: Commercial & Shareholder Litigation, Corporate Advisory & Tax Compliance, Estate & Gift Valuation, Matrimonial Valuation & Litigation Support, Uncategorized
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. As you may recall in my prior article published in the American Bar Association’s eReport to its Trust & Estates and Real Property Sections titled, “A Primer on the Valuation of Hedge Fund and Private Equity Fund Management Interests,” we noted that General Partners or
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Extended Thoughts on the IRC 2704 Proposed Regulations
- August 5, 2016
- Category: Corporate Advisory & Tax Compliance, Estate & Gift Valuation, Uncategorized
By Matthew E. Rappaport, Esq. LL.M – Tax Planning & Structuring Attorney In the wake of the Internal Revenue Service releasing Proposed Regulations pertaining to IRC 2704 yesterday, I have received many questions and conducted many discussions about the Proposed Regulations’ content and potential impact. I posted a short status update about my preliminary thoughts
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A Primer on the Valuation of Hedge Fund and Private Equity Fund Management Interests
- July 7, 2016
- Category: Corporate Advisory & Tax Compliance, Estate & Gift Valuation, Matrimonial Valuation & Litigation Support
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. Attorneys who represent clients in estate planning matters or marital dissolution cases may discover that their clients are in the business of owning and/or managing alternative assets. Two of the most common types of alternative assets are private equity funds and hedge funds. While their
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The Valuation of Start-Up or Early-Stage Companies: Marital Dissolution Considerations
- July 7, 2016
- Category: Estate & Gift Valuation, Matrimonial Valuation & Litigation Support
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. The valuation of start-up companies often involves unique complexities that must be considered by an expert when undertaking such an engagement. In the context of a divorce proceeding, there are two valuation issues that must be addressed: What is the value of the company in