Case Summaries Estate of Aaron U. Jones v. Commissioner, T.C. Memo. 2019-101

Ronald D. Aucutt

Aug 26, 2019
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The opinion of Tax Court Judge Pugh in Jones, regarding the gift tax value of interests in passthrough entities conducting a timber business, is the first time in 20 years that the analysis and judgments of taxpayers’ valuation experts about “tax-affecting” the earnings of S corporations and other passthrough entities appear to have found an understanding audience in the Tax Court.  In addition, the opinion reinforces recent trends rejecting the use of an asset-based approach to valuation of operating businesses, especially in a business with very long yield cycles like the timber industry.

Senior Fiduciary Counsel
Ron is responsible for working with clients and their advisors to develop practical and efficient wealth transfer plans, and for guiding the firm on fiduciary issues.