On May 21, 2009, the respondent issued a notice of deficiency to the Estate of John F. Koons III, determining a deficiency in estate tax of $42,771,586.75 and a notice of deficiency to the John F. Koons III Revocable Trust, determining a deficiency in generation-skipping transfer tax of $15,899,463....   MORE>>

Plaintiffs-Appellants American Premier Underwriters, Inc. and American Financial Group, Inc. (collectively APU ) appeal the district court s dismissal of five of its claims against Defendant-Appellee National Railroad Passenger Corporation ( Amtrak ). For the following reasons, we reverse...   MORE>>

This case is before the Court on a petition for redetermination of two separate deficiencies. Respondent determined that the estate is liable for (1) a $9,818,040 estate tax deficiency and a $2,817,294 section 6662 penalty and (2) a $3,784,333 gift tax deficiency and a $722,573 section 6662 penalt...   MORE>>

MichaelJosephKrzyzaniakpleadedguiltytowirefraudandincometaxevasion in violation of 18 U.S.C. 1343 and 26 U.S.C. 7201. Krzyzaniak admitted in a lengthy plea agreement that he conducted an eight-year scheme to defraud many persons by inducing themto invest more than $20 million in airport Inte...   MORE>>

On remand from the U.S. Court of Appeals for the Fifth Circuit for further proceedings in accordance with its opinion in Whitehouse Hotel Ltd. P'ship v. Commissioner, 615 F.3d 321 (5th Cir. 2010), vacating and remanding 131 T.C. 112 (2008), we reconsider the value of the qualified conservation contr...   MORE>>

H & M, Inc. is a small corporation that sold its biggest asset, an insurance-brokerage business, to a local bank in 1992. H & M s owner kept the corporation active--he says--to exploit his two patented inventions. He himself went to work for the bank that bought the brokerage business, and...   MORE>>

This appeal arises from a bankruptcy court order in which the bankruptcy court concluded that, for purposes of determining the value of the secured portion of the claims of Bank of America, N.A. ( Bank ) pursuant to 11 U.S.C. 506(a), a determination of the fair market value of various apartme...   MORE>>

This appeal requires us to decide how bankruptcycourts should value collateral retained by a Chapter 11 debtorin order to determine the amount of a creditorâ s secured claimunder 11 U.S.C. § 506(a). Appellants, a group of creditorsknown as the Cornerstone Investors, claim that theB...   MORE>>

Albert Trostel & Sons Company (Trostel) was founded in 1858. By 2007 the founder s relations still owned about 11% of its stock. Everett Smith Group, Ltd. (Smith), which owned the other 89%, decided to acquire the remaining shares via a freezeout merger. Voting was a formality; Smith s share...   MORE>>

Falcon Holdings was organized in 1999 to own and operate 100 fast-food restaurants. Aslam Khan owned 40% of Falcon s common units. (Falcon is a limited liability company rather than a corporation; ownership is represented by units rather than shares.) The remainder of the common units, and all of ...   MORE>>