Defining Value in a Formula Gift Clause

There’s something for nearly everyone in the U.S. Tax Court and the U.S. Court of Appeals for the Fifth Circuit opinions in Nelson v. Commissioner.¹ Most notably, the cases highlight a dispute over the efficacy of defined value language in gift transfer documents. In this regard, Nelson joins a long list of such cases.² From a valuation standpoint, the Tax Court dealt with a wide range of issues, including the valuation of holding companies, minority