In Estate of Franklin Z. Adell v. Comm., TCM 2014-155 (08/04/14), in light of the fact that the goodwill of a C corporation was attributable to the son of the decedent with whom the corporation did not have a covenant not to compete and or other agreement, the Tax Court determined that the stock of the decedent was worth only 9.3M and not 26M as the government argued. As far as I know, this is the first case involving personal goodwill in an estate tax context and the concept of personal goodwill appears to have saved the estate between 10M and 15M of estate taxes. If you would like to learn more about how to use personal goodwill to save both income taxes and estate taxes, consider attending our 1/2 day seminar on 06/11 from 1:30pm-5:00pm in Waltham. If you also would like to learn something about complete liquidations of S corporations and C corporations, consider attending our 1/2 day seminar entitled Complete Liquidations from 9:00am-12:30pm on 06/11 in Waltham. Please remember that two 1/2 day seminars on the same day are only $225 and not $150 for each seminar!
I have not looked at the Adell case yet, but I think you may see something on it on forbes.com next week. I sometimes leave out the notices about seminars from the BTI when I get behind in posting the blasts, but this one is timely. Personal goodwill is a powerful technique that many people are unaware of, but it has stood up well in decisions.
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