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Defining Value in Formula Gift Clause

The US Tax Court and the US Court of Appeals for the Fifth Circuit have something for almost everyone. Nelson v. Commissioner1 Most notably, the cases highlight controversy over the efficacy of value language defined in gift transfer documents. In this regard, Nelson Join the long list of such cases.2 From a valuation standpoint, the Tax Court dealt with a wide variety of issues, including valuation of holding companies, minority

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