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is a Managing Director of FMV Opinions. Inc.. a national valuation and investment banking firm with offices in New York. San Francisco, Irvine. and Dallas. Mr. Hall heads up FMV's estate and gift tax valuation practice. He may be reached at lhafird.fmv.com. Additional information regarding FMV Opinions
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
is a Managing Director of FMV Opinions. Inc., a national valuation and investment banking firm with offices in New York, San Francisco, Irvine, and Dallas. Mr. Hall heads up FMV's estate and gift tax valuation practice. He may be reached at lhallAfmv.com. Additional information regarding FMV Opinions,
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
rk, 336 U.S. 106, 110 (1949) ("It is no re- quirement of equal protection that all evils of the same gius be eradicated or none at all."); see also Dallas Stanglin, 490 U.S. 19, 26 (1990) ("(A] State does not violate the Equal Protection Clause merely because the classifications made by its laws Pag
preserved his right to urge an acquittal based on any shortcomings or missteps in the presentation of the government's case. See United States v. Sumner, 119 F.3d 658, 660 (8th Cir.1997) ("(Al general denial defense ... forces the government to prove every element of the crime charged.") (7) Th
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