Gift tax valuations

Forbes Informer reports that former Dell Vice Chairman Morton Topfer transferred cash and stock into trusts for his children and grandchildren, a transfer he valued at $3.5 million. Apparently he traded with the trusts as well, transactions that the IRS now says had no legitimate business purpose. Sounds like a complex plan for cooking up some discounts.

In any event, the IRS valued the transfers over two years at $105 million (I'm guessing that figure is close to the current value of the trusts). Accordingly, they would like $65 million in additional gift tax payments. Topfer is resisting with a Tax Court suit. I'm looking forward to reading that decision.

Somehow I suspect that Mr. Topfer won't be joining Warren Buffett in arguing for a retention of the federal estate and gift tax systems.

Hat tip to Professor Beyer.