Gift tax, estate tax, gift, estate, tax, merger, estate planning, penalties, valuation
In Cavallaro v. Commissioner, the Tax Court held that a merger of two family-owned businesses resulted in a substantial taxable gift. The taxpayers avoided penalties by demonstrating that they relied in good faith on the mistaken advice of competent tax advisers.
Ryan, Kerry A., Merger is Indirect Gift in Cavallaro (January 19, 2015). Tax Notes, Vol. 146, No. 1, 2015.