Todd will be co-presenting with attorney David Aughtry of Chamberlain Hrdlicka on “How Cecil Validates Everything You Do for Families” which will review the important 2023 USTC decision in Cecil v. Commissioner. The subject of the case were the 2010 transfers of non-controlling interests in The Biltmore Company by descendants of the Vanderbilt family.
Two primary valuation issues were addressed: (i) whether it was appropriate to apply an entity level tax burden to a pass-through entity and (ii) whether it was appropriate to appraise a non-controlling interest in an asset-intensive hospitality company using an asset approach. Messrs. Aughtry and Povlich will review the case in detail and discuss a variety of estate planning and valuation takeaways.
In addition to Todd, MPI will be represented by Tadd Lindsay at the meeting.
For case details go to https://dawson.ustaxcourt.gov/case-detail/14640-14