§10402

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4 Citing Cases

to acquire or use property at less than fair market value, or limitations on sale or use of property) on valuation for estate and gift tax purposes.35 See sec. 2703. New section 2703 34See Omnibus Budget Reconciliation Act of 1987, Pub. L. 100-203, sec. 10402, 101 Stat. 1330-431. 35SEC. 2703. CERTAIN RIGHTS AND RESTRICTIONS DISREGARDED. (continued...) - 80 - applied to agreements, options, rights, or restrictions entered into, granted, or substantially modified after October 8, 1990.36 See OBRA

Jean D. True, Petitioner T.C. Memo. 2001-167 · 2001

to acquire or use property at less than fair market value, or limitations on sale or use of property) on valuation for estate and gift tax purposes.35 See sec. 2703. New section 2703 34See Omnibus Budget Reconciliation Act of 1987, Pub. L. 100-203, sec. 10402, 101 Stat. 1330-431. 35SEC. 2703. CERTAIN RIGHTS AND RESTRICTIONS DISREGARDED. (continued...) - 80 - applied to agreements, options, rights, or restrictions entered into, granted, or substantially modified after October 8, 1990.36 See OBRA

luation rules, of which section 2704 is a part, were enacted in OBRA 1990 section 11602(a), in conjunction with the repeal of section 2036(c).9 The latter provision, enacted as part of the Omnibus Budget Reconciliation Act of 1987, Pub. L. 100-203, sec. 10402(a), 101 Stat. 1330, 1330-431, represented Congress' attempt to discourage taxpayers' use of “estate freeze” transactions for the purpose of reducing or avoiding Federal transfer taxes. See H. Conf. Rept. 100-495, at 994 (1987), 1987-3 C.B.

Estate of Graves v. Commissioner 92 T.C. 1294 · 1989

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