Valuation Discounts After Estate of Nowell v. Commissioner: A Clear Formula for Reducing Estate Taxes

In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on property for purposes of calculating federal estate and gift tax liability. In its memorandum opinion, the court held that transferred property is valued without considering other similar property held by either the transferor or transferee for estate and gift tax purposes. The Nowell decision provided two important rules. First, a family may transfer property to various trusts and then claim that the total value of all trusts is worth less than the value of the underlying property because each trust owns only a partial share of the property. This is true even when the family still owns and controls the trusts and, therefore, owns and controls all the property. Second, Nowell provides an additional valuation discount when an interest in a limited partnership is transferred and the transferee is treated as an assignee as opposed to a substitute limited partner. This discount is available even when the transferee owns one hundred percent of the remaining partnership, making the distinction between an assignee and a full partner irrelevant. Part II of this note will discuss the relevant law as it existed at the time Nowell was decided. Parts III and IV will then describe the circumstances surrounding the case and how it came to be heard by the court. Next, Part V will offer an explanation of the Tax Court\u27s analysis, which will then be critiqued and supported in Part VI. Part VII will conclude this note by discussing a method by which to use the Nowell case to obtain maximum valuation discounts in estate planning

Valuation Discounts After Estate of Nowell v. Commissioner: A Clear Formula for Reducing Estate Taxes

In Estate of Nowell v. Commissioner, the Tax Court considered the issue of valuation discounts on property for purposes of calculating federal estate and gift tax liability. In its memorandum opinion, the court held that transferred property is valued without considering other similar property held by either the transferor or transferee for estate and gift tax purposes. The Nowell decision provided two important rules. First, a family may transfer property to various trusts and then claim that the total value of all trusts is worth less than the value of the underlying property because each trust owns only a partial share of the property. This is true even when the family still owns and controls the trusts and, therefore, owns and controls all the property. Second, Nowell provides an additional valuation discount when an interest in a limited partnership is transferred and the transferee is treated as an assignee as opposed to a substitute limited partner. This discount is available even when the transferee owns one hundred percent of the remaining partnership, making the distinction between an assignee and a full partner irrelevant. Part II of this note will discuss the relevant law as it existed at the time Nowell was decided. Parts III and IV will then describe the circumstances surrounding the case and how it came to be heard by the court. Next, Part V will offer an explanation of the Tax Court\u27s analysis, which will then be critiqued and supported in Part VI. Part VII will conclude this note by discussing a method by which to use the Nowell case to obtain maximum valuation discounts in estate planning

Protecting Preteens on Facebook: An Exploratory Examination of Parental Mediation Strategies for Children’s Facebook Use in Singapore

Children are particularly vulnerable to the risks of going online, yet the profile of the child Internet user is becoming younger, particularly on social media. Parental mediation describes efforts by parents to translate the complexities of the physical/social environment as well as mass media into terms that children at various levels of cognitive development can understand. This exploratory study examined parental mediation strategies as predictors of parents’ intention to control underage use of Facebook in Singapore, a country with high internet penetration but little data protection regulation. The study found that parents with mediation styles that were highest on Regulated mediation (Restrictive and Selective mediation) as well as parents whose eldest child was female showed the highest level of intentions to control underage Facebook usage. Additionally, the younger the age group of the eldest child in the family, the more likely parents were to express intentions to control Facebook usage

Efficient Part Load Combined Cycle Operation.

LecturePg. 31-36During the oil crisis in the 1970s, many electric utilities assigned their base load portion of electric generation requirements to nuclear and coal fired steam plants. The intermediate duty in some cases was assigned to combined cycles or to oil fired steam plants. The peak duty under 1000 hr was assigned in many cases to combustion turbines. By innovative boiler modification, the peaking combustion turbine can be combined with a steam plant to provide the combustion air for the steam plant boiler with a wide load variation at good efficiency. In addition to maintaining high efficiency at part load, it increases the plant capacity 6 to 7 percent at full load, decreases NO(subscript x) generation, varies the air flow to an existing boiler 10 percent and up to 20 percent using a new combustion turbine and provides a system such that the gas turbine can automatically be removed from the cycle without tripping the steam cycle

Farmers, Lenders and Water Districts Response to Texas

There are 6.4 million irrigated acres in Texas with 80 percent irrigated from ground water and 20 percent irrigated from surface sources. This is compared to 8.6 million acres irrigated in 1979, a dramatic reduction. Total acre feet of water applied annually is approximately 8.8 million. This is 60-65 percent of all water use in Texas. However, irrigated land contributes about $2.0 billion of output annually which has an economic impact to the state of over$6.0 billion. Thus, irrigation is important to the economy of Texas and particularly to the economic viability of rural communities over much of the state. There was a time when water was plentiful and there were only a limited numbers of users. With urbanization and growth in industry, water has become a limited resource. Continued pumping from the Ogallalla results in a declining water table. Urban demands in many areas have drawn heavily upon available supplies. The importance of water to the continued growth of agriculture, municipal and industrial sectors emphasizes the critical need for efficiency in use. The Texas Legislature enacted a program whereby low interest loans could be made available for the purchase of water conserving (more efficient) irrigation equipment. This was called the "Agricultural Water Conservation Loan Program." The legislation is covered under Texas Administrative Code sections 367.70-367.79 and are promulgated under the authority of the Texas Water Code, sections 6.101 and 17.903

Black Gold or Black Hole? The Effects of Oil on the Informal Economy

Does oil revenue enlarge or diminish the size of a country’s informal economy? I examine the effects of oil revenue on informal economy size for all available countries and by studying the case of Ghana, which had little oil before a large find in 2007. I first construct an estimate of the informal economy using a confirmatory factor analysis modeling approach based on robust model runs and careful theoretical consideration. Then I analyze the domestic determinants of the informal economy and add to the literature by finding that oil revenues do negatively impact a country’s informal economy through the rentier effect channel. This is to say that if taxes go down as a result of oil rents, the informal economy will grow larger. Next, I analyze foreign determinants and find the oil rents have a larger negative impact on the informal economy in countries with lower levels of industrialization. I augment these findings with a case study of Ghana, and use process tracing and qualitative methods to analyze the oil find’s effects on the Western Region. The relationship between a country’s oil rents and its informal economic activity has not been studied to this point, and these results can help policymakers understand and prevent oil rents from creating a larger informal economy. Utilizing exogenous variation in oil revenues, I find strong support for my hypothesis