Scarinci Hollenbeck, LLC
The Firm
201-896-4100 info@sh-law.comFirm Insights
IRS Defends $2 Billion Tax Dispute with Bill Davidson's Estate
Author: Scarinci Hollenbeck, LLC
Date: September 9, 2013
Key Contacts
Back
The Internal Revenue Service is not backing down on a tax dispute claiming that the estate of the late Piston’s owner Bill Davidson owes more than $2 billion in estate taxes. The agency said the large estate bill is the result of Davidson’s misuse of gift tax law and his underpayment for sizable gifts made to family members. The agency is also disputing the value of stocks put in trusts for his heirs.
Davidson’s estate representatives contend that they do not owe the IRS anything more than what they have already paid in estate taxes, and the dispute is likely to play out in court as both parties are unwilling to concede. The estate asserts that the federal tax agency has greatly inflated the tax bill – which is approximately $2.8 billion, according to the Detroit Free Press. However, the agency fired back in a U.S. Tax Court in Washington, and said that Davidson failed to report on large gifts and did not properly value certain investments passed on to beneficiaries.
For instance, the agency argues that Davidson failed to use the same standards and methods of establishing value of stocks that the IRS uses. In addition, it charges that Davidson’s life expectancy was a key determination in establishing the value of self-canceling installment notes, the newspaper reports. With these notes, Davidson could essentially transfer assets to family members, who would make payments on the assets while Davidson lived. After his death, the family members would own the assets outright.
Although physicians gave Davidson a clean bill of health in the months before his death and presumed that he had several years left in his life expectancy, the agency – which uses life expectancy to determine whether payments are taxed or considered gifts – claims that these amounts are taxable.
- Practices: Tax and Trusts & Estates, Sophisticated Estate Planning & Wealth Preservation
- Locations: Red Bank, NJ, New York City, Little Falls, NJ
No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.
Related Posts
See all
Rule 26 Expert Discovery: When an Expert Witness Uses AI, Is It Discoverable?
Case law following the 2010 amendments to Federal Rule of Civil Procedure 26 offers guidance on how courts are likely to address whether an expert witness’s AI records are subject to discovery. Key Takeaways Rule 26 Expert Discovery After the 2010 Amendments This article addresses the question courts and lawyers have faced in recent cases: […]
Author: Chris Seelinger
How Expert Witness AI Use Ends Up in Discovery
“Show how 3M is 0% at fault.” The absurd tale of how a 350-page ChatGPT history for 3M’s expert witness was produced during a deposition is more likely than you think. It’s an inevitable trend, and an unsettled question for federal courts as experts make generative AI part of their workflow. Key Takeaways Expert Witness […]
Author: Chris Seelinger
The Screenshot Problem: Why Nothing Is Really Private Anymore
Screenshots have changed the risks of electronic communications. The screenshot problem is that messages intended for one person or a small group can be copied, forwarded, preserved, and ultimately presented to opposing counsel, regulators, journalists, customers, or a jury. Businesses should recognize that a truly private digital conversation is increasingly unreliable and ensure their policies, […]
Author: Sean M. Pena
BESS Project Agreements: Allocating Risk Among Developers, EPC Contractors, and Equipment Suppliers
Developers, engineering, procurement, and construction (EPC) contractors, and equipment suppliers each play a critical role in completing a BESS project. However, when equipment costs rise, deliveries are delayed, or regulations change, determining who bears the financial consequences can become contentious. Well-drafted project agreements are essential to sound risk allocation. Key Takeaways This article is Part […]
Author: Nicholas Wall
IP Infringement: What Steps Can You Take If You're Affected?
IP infringement occurs when someone uses your intellectual property without your permission or beyond the scope of the permission you granted. Common examples of IP infringement include copying a product’s patented features or using a trademarked logo in a way that is likely to confuse consumers about the source or affiliation of goods or services. […]
Author: Michael Mietlicki
Public Allegations, Unfinished Investigation: What New Jersey Businesses Should Do Next
When facing public allegations of wrongdoing, companies should not let the speed of the public conversation dictate the speed of an investigation. An investigation designed to confirm a preferred narrative rather than establish the facts can create serious problems later, particularly if litigation, regulatory scrutiny, or employment claims follow. Key Takeaways When public allegations surface […]
Author: Sean M. Pena
No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.
Sign up to get the latest from our attorneys!
Explore What Matters Most to You.
Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.
Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.