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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

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