Epstein Secrets

S. Hall, ASA! A few weeks ago, the Tax Court released its decision in the case of Edward Redstone v. Commissioned. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave

ding Edward with his stock certificates, Mickey argued that there was an oral EFTA00668064 agreement that some of the stock was for the benefit of Edward's children, and not for Edward. To bolster this argument, Mickey pointed out that he had contributed 48 percent of NAI's capital and had only receive

the case of Edward Redstone v. Commissioned. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave revenge. Backgrounda In the mid 1960s, Edward owned a one-third int

EFTA00668065 However, at Sumner's trial, the Tax Court stated, There is no evidence that any dispute existed in 1971-1972 concerning ownership of Sumner's stock or that Mickey was determined to withhold any of Sumner's shares from him. To the contrary: the evidence showed that Mickey and Sumner were

outsider. He also refused to repurchase Edward's shares, without Edward's explicit acknowledgement of the "oral trust." Soon, full-blown litigation ensued. This greatly embarrassed the family, es

outsider. He also refused to repurchase Edward's shares, without Edward's explicit acknowledgement of the "oral trust." Soon, full-blown litigation ensued. This greatly embarrassed the family, especially Edward's mother

, There is no evidence that any dispute existed in 1971-1972 concerning ownership of Sumnees stock or that Mickey was determined to withhold any of Sumner's shares from him. To the contrary: the evidence showed that Mickey and Sumner were working in concert to drive Edward out of the company and that

ior Court and the Court "issued a Final Decree incorporating the terms of the Settlement Agreement." Three weeks after the Final Decree was issued, Sumner, in support of his father's wishes, "executed irrevocable declarations of trust for the benefit of his two children" and transferred a similar amoun

for not providing Edward with his stock certificates, Mickey argued that there was an oral agreement that some of the stock was for the benefit of Edward's children, and not for Edward. To bolster this argument, Mickey pointed out that he had contributed 48 percent of NAI's capital and had only received

Hall, ASA* A few weeks ago, the Tax Court released its decision in the case of Edward Redstone v. Commissionerill. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave

he case of Edward Redstone v. Commissionerill. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave revenge. Background' In the mid 1960s, Edward owned a one-third int

gift tax return because of the Final Decree. Since Sumner was relying on the advice of competent professionals, no penalties were added. Somewhere, Edward is smiling. W T.C. Memo. 2015-237 (December 9, 2015) * Mr. Hall is a Managing Director of FMV Opinions. Inc., a national valuation and investment b

ermined in the Final Decree. In regards to any penalties for not declaring a gift, participants from the firm that provided accounting services for Sumner and NAI some 40 plus years ago, testified about uncertain memories and vague discussions with now deceased partners. A key memory, however, was the