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Grant of Easement in Family Farm Triggers Section 2032A Recapture Tax: Estate of Gibbs v. United States

In Estate of Gibbs v. United States, the U.S. Court of Appeals for the Third Circuit held that the grant of a development easement to the State of New Jersey constituted a disposition of an interest in the taxpayer's family farm and triggered a recapture of estate taxes under section 2032A. Gibbs is the first published decision to construe the "disposes of any interest" language in section 2032A(c)(1)(A). ...

Fair Market Value of Appreciated Property Distribution to Shareholders Determined Based on Form of Distribution Out of Corporation, Not on Form Received by Shareholders: Pope & Talbot, Inc. v. Commissioner

In Pope & Talbot, Inc, v. Commissioner, the Ninth Circuit held that the corporate taxpayer's gain on the distribution of appreciated property to a newly formed limited partnership, which then distributed limited partnership interests pro rata to the corporation's shareholders, was determined by reference to the value of the appreciated property...

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