Price determination of goodwill

Tax Court Upholds Defined Value Gift Formula Clause in Wandry v. Commissioner, T.C. Memo 2012-88 (March 26, 2012)  April 14, 2011 – 12:28 pm
Pictures Formula clauses are used by taxpayers to avoid unintended gift, estate and generation-skipping transfer (GST) tax consequences when transferring property. There are two general types of formula clauses: A definition clause defines a transfer by reference to the value of a possibly larger, identified property interest; and a savings clause retroactively adjusts the value of a transfer due to a subsequent valuation determination.
he IRS has been successful challenging savings clauses for gift, estate and GST tax purposes, arguing that they are against public policy because they prevent the IRS from properly administering the Code. The definition clause is a relatively new type of clause that has generally been respected by courts for gift, estate and GST tax purposes.
In Wandry, a couple established an FLP and embarked on an annual program of gifting interests to a FLP. Their estate planning attorney advised them that (1) the number of FLP units equal to the desired value of their gifts on any given date could not be known until a later date when a valuation of the FLP's assets could be made; (2) all gifts should be given as specific dollar amounts rather than specific numbers of membership units; and (3) all gifts should be given on Dec. 31 or Jan. 1 of a given year,

Source: Business Valuation Blog

Algonquin Books When Tito Loved Clara
Book (Algonquin Books)

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House Session 2011-07-07 (16:05:07-17:05:41)
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Mihai Viteazul / 1970 - 1 (eng, fr sub)
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Authors@Google: Eric Pooley
Authors@Google: Eric Pooley

Your opinion you can keep - let's see some data

You know man, there's a lot of people who can think for themselves. If you really want to share this data and the data is factual, then post it, or link to it. What you've posted is a bit like an editorial. It's your take and I personally prefer to do the interpretation myself. I can tell you that the studio I moved in to in 1998 was priced at $725 then and it's being advertised at the low low p...explain this course of action though I can admire their committment to their chosen course of action regardless of it's financially unsound nature.
I must say the landlords aren't garnering a whole lot of goodwill these days. Hooray for Rent Control. Up with tenent rights and down with landlord tyranny. Speak your mind publicly or forever hold your piece (spelling intended).

Does RIM's Patent Shelf Life Affect its Valuation?  — Trefis
Given RIM's own price per patent valuation at a similar multiple as the Nortel deal, and a 27% premium over the Motorola Mobility deal, Envision IP calculated the remaining patent terms of each patent portfolio to understand one of the reasons why RIM …

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Research In Motion May Burn Close To $1B Cash On BB10  — Seeking Alpha
If you assume that the entire handset business including all inventories is worth $1B, coupled with a decreased network value of $1B, and a very conservative patent valuation of $2B, RIMM is still worth $10. The only scenario that matches a $6 …

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