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Value Price Auto, Llc is a small organization in the new and used car dealers industry located in Phoenix, AZ. It opened its doors in 2012 and now has an estimated $179,745 USD in yearly revenue and approximately 4 employees.
The value of both the gifts and the sales were based on independent valuations that included a discount for lack of marketability of approximately 37%. The IRS claimed that the entity should be disregarded for gift tax purposes resulting in a direct gift of the cash to the trusts.Taxpayer argued that the LLC should not be disregarded for gift tax purposes. The full Court reviewed the case and the majority held in favor of the taxpayer.o. 2), the court dealt with the issue as to whether a single-member LLC is to be disregarded for transfer tax purposes (i.e., gift tax purposes), thus treating the gift as a direct gift of the underlying property of the LLC.