TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

In Connelly v. United States, the U.S. Supreme Court examined an estate-tax issue involving how to value life insurance proceeds received by a closely held corporation upon a principal shareholder’s death. Typically, such proceeds are used by the corporation to buy back shares from the deceased shareholder’s estate, thereby keeping the corporation in the family. The parties stipulated that the insurance proceeds were an asset that increased the value of the corporation. The Court had to decide whether the corporation’s contractual obligation to purchase the deceased shareholder’s shares offset the life insurance proceeds.

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Founded in 1960, Hochman Salkin Toscher Perez, P.C., is internationally recognized as the preeminent tax law firm on the West Coast. The reputation of the firm for excellence and integrity in the tax community is unparalleled. The firm specializes in federal and state civil and criminal tax litigation, tax controversies and tax disputes with the federal, state, and local taxing authorities and white collar criminal defense, and has received many notable decisions on behalf of its clients before the Federal Appellate Courts, the Federal District Courts, the Bankruptcy Courts, the United States Tax Court, and various state courts, including the California Franchise Tax Board California Department of Tax and Fee Administration and the
California Employment Development Department.