The Tax Court calculated the discounts for lack of control and marketability for a family limited partnership and a 50% interest in a related general partnership owned by the FLP.

The Eleventh Circuit overturned the Tax Court and allowed the estate a dollar-for-dollar reduction in fair market value for the hypothetical tax on trapped-in gains for a "C" corporation minority shareholder.

Citing the incompetence of the valuation experts, the 2nd Circuit remanded for the Tax Court to determine if reliance on appraisers was reasonable and in good faith for purposes of an accuracy related penalty.

The Tax Court concluded that warrants had an ascertainable fair market value in 1995 and were taxable in that year.

The Tax Court rejected tax-affecting S Corporation earnings, concluding a stock transaction was a bargain sale and thus a gift.

The Tax Court determined that sales of shares between family members in a closely held corporation were arm's-length transactions and supported the prices used for gift tax returns.