{"id":3116,"date":"2023-06-29T21:42:55","date_gmt":"2023-06-29T21:42:55","guid":{"rendered":"https:\/\/mysourcefunding.com\/tax-preparation\/8th-circuit-includes-insurance-proceeds-for-redemption-in-estate-tax-valuation-of-closely-held-company\/"},"modified":"2023-06-29T21:42:56","modified_gmt":"2023-06-29T21:42:56","slug":"8th-circuit-includes-insurance-proceeds-for-redemption-in-estate-tax-valuation-of-closely-held-company","status":"publish","type":"post","link":"https:\/\/mysourcefunding.com\/?p=3116","title":{"rendered":"8th Circuit Includes Insurance Proceeds For Redemption In Estate Tax Valuation Of Closely Held Company"},"content":{"rendered":"
\n

A recent case demonstrates the impact that a stock-purchase agreement and life insurance can have (or not have) on the valuation of a closely held company for estate tax purposes.<\/p>\n

Before diving into the case, some context is helpful. It is not uncommon for closely held businesses to have buy-sell agreements. In many instances, the other owners are the main market to sell your shares when you exit, and that exit may include death. Thus, these agreements can provide for a \u201ccross-purchase\u201d option, which means that the other owners purchase the exiting owner\u2019s interest. Another option is a redemption, which means that that the business purchases (redeems) the exiting owner\u2019s interest.<\/p>\n

As part of these agreements, there is typically a price setting mechanism (to determine the buyout price). For estate tax purposes, if the decedent owned an interest in the business, that value is included in the gross estate. A critical issue then arises of whether the price set by the buyout agreement is binding for estate tax purposes. That issue is resolved by \u00a7 2703 and is discussed more below. Practically, the owners also want a liquidity source to help pay for the buyout; that may be accomplished by life insurance.<\/p>\n

In particular, this case explores when a court will respect an agreement under \u00a7 2703, and how the presence of life insurance proceeds affect the valuation of the company for estate tax purposes.<\/p>\n

With that context, let\u2019s get to the case.<\/p>\n

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In the case, two brothers were the sole shareholders of a corporation; one brother owned about 77% of the company and the other brother owned the rest. The brothers had a stock-purchase agreement. Under the agreement, upon the death of a brother, the surviving brother could purchase the shares. If the surviving brother opted not to, the company had to redeem the shares. As well, the corporation purchased life insurance on the brothers so that the policy proceeds could be used to fund such a redemption. The purpose of this planning, of course, was to ensure that control would stay within the family. Moreover, according to the court, the brothers intended the company to effectuate the redemption, rather than a surviving brother effectuating the cross-purchase option.<\/p>\n

Under the stock-purchase agreement, there were two ways to determine the redemption price. The first method was that, at the end of each tax year, the brothers would agree to price per share in a \u201cCertificate of Agreed Value.\u201d And, if such annual agreement did not occur, the agreement required two or more appraisals. However, the brothers did not do either of these options. Despite that, the company purchased $3.5 million of life insurance on each brother.<\/p>\n

The majority-owner brother died in 2013. After his death, the company received the life insurance proceeds and redeemed his shares for $3.0 million, the price of which was resolved by the family without any appraisal. The remaining life insurance proceeds ($500,000) was used for corporate operations.<\/p>\n

On the brother\u2019s estate tax return, the shares in the company were valued at $3 million\u2014the price of the redemption payment. Upon an audit, the Service concluded that the estate undervalued the company by relying on the redemption payment instead of valuing the company and including the value of the life insurance proceeds as a corporate asset. The IRS determined that the company was worth about $6.86 million. In particular, the IRS valued the deceased brother\u2019s shares at $2,982,000, exclusive of the life insurance. Given his 77.18% ownership, this represents a company value of $3.86 million. It then added the $3 million in proceeds for the redemption. Importantly, the court noted that the estate did not challenge the \u201csans-proceeds\u201d valuation on appeal, and thus accepted it for purposes of the appeal.<\/p>\n

Based on the IRS\u2019s valuation, then, the deceased brother had a 77.18% interest in a $6.86 million company, meaning the interest was worth about $5.3 million. The IRS sent a notice of deficiency for the additional tax. After paying the deficiency, the estate sued for a refund. The district court granted summary judgment for the government, which the estate appealed to the Eighth Circuit.<\/p>\n

The estate advanced two arguments. The first was that the redemption transaction, under the stock-purchase agreement, set the price for estate-tax purposes, and therefore no valuation was needed. The second argument was that the valuation should not include the life insurance proceeds because although the proceeds may have represented an asset, they were offset by the redemption obligation, which was a liability. For its part, the government countered that the stock-purchase agreement should be disregarded. It also argued that any calculation of fair market value must account for the insurance proceeds.<\/p>\n

Undoubtedly, the brother\u2019s gross estate included his corporate shares (see<\/em> \u00a7 2033). Thus, the real issue in the case is the proper valuation of those shares. And, more acutely, the issue is about the inclusion of the life insurance proceeds as part of that valuation.<\/p>\n

The court first considered whether the stock-purchase agreement controlled the valuation of the company for estate-tax purposes. Under \u00a7 2703(a), the value of property is determined without regard to \u201cany option, agreement, or other right to acquire or use the property at a price less than the fair market value of the property (without regard to such option, agreement, or right)\u201d and \u201cany restriction on the right to sell or use such property.\u201d In other words, \u00a7 2703(a) essentially says to ignore the stock-purchase agreement, unless certain criteria are met, which are set forth in subsection (b). Under subsection (b), the agreement must meet three requirements. First, it must be a \u201cbona fide business arrangement.\u201d Second, it must not be a \u201cdevice to transfer such property to members of the decedent\u2019s family for less than full and adequate consideration in money or money’s worth.\u201d And third, \u201c[i]ts terms are comparable to similar arrangements entered into by persons in an arms\u2019 length transaction.\u201d<\/p>\n

The estate argued that its stock-purchase agreement satisfied these criteria. The court, however, disagreed. The court noted that the agreement was missing a critical component, namely a fixed or determinable price to consider for valuing the shares. As explained by the court, \u201cif \u00a7 2703 tells us when we may \u2018regard\u2019 agreements to acquire stock \u2018at a price less than the fair market value,\u2019 we naturally would expect those agreements to say something<\/em> about value in a definite or calculable way.\u201d<\/p>\n

Here, the court emphasized that the stock-purchase agreement set forth no fixed price or even prescribed a formula for determining a price. Rather, the agreement set forth two ways in which the brothers may have agreed to a price. And, the court, rejected the estate\u2019s entreaty to fix the price by the redemption transaction because it linked back to the stock-purchase agreement. In this vein, the court noted that the price was chosen after the death, and, moreover, that price came not from the purchase agreement, but rather the family\u2019s agreement to resolve estate-administration matters.<\/p>\n

In sum, for the first issue, the court determined that the corporation\u2019s value must be determined without regard to the stock-purchase agreement under \u00a7 2703(a).<\/p>\n

The court then turned to the second issue, which it framed as \u201cwhether the life insurance proceeds received by [the company] and intended for redemption should be taken into account when determining the corporation’s value at the time of [the brother\u2019s] death.\u201d<\/p>\n

Among other things, the court noted that, in valuing a closely held corporation, the Treasury Regulations provide that \u201cconsideration shall also be given to nonoperating assets, including proceeds of life insurance policies payable to or for the benefit of the company, to the extent such nonoperating assets have not been taken into account in the determination of net worth, prospective earning power and dividend-earning capacity.\u201d 26 C.F.R. \u00a7 20.2031-2(f)(2)<\/p>\n

As mentioned earlier, the estate argued that the life insurance proceeds did not augment the company\u2019s value because the proceeds were offset by the redemption liability. The court, however, explained that \u201c[a]n obligation to redeem shares is not a liability in the ordinary business sense.\u201d To do so, it continued, would distort the nature of the ownership interest. In an example, the court noted that, at the brother\u2019s death, a willing buyer could obtain all the shares and then just extinguish the agreement or redeem the shares from himself. The court said this \u201cis just like moving money from one pocket to another.\u201d In other words, the court explained \u201c[t]here is no liability to be considered\u2014the buyer controls the life insurance proceeds.\u201d As applied here, the court explained that a buyer would pay $6.86 million, which takes into account the life insurance proceeds, and then could extinguish or redeem. The court furthermore noted that \u201ca hypothetical willing seller of [the company] holding all 500 shares would not accept only $3.86 million knowing that the company was about to receive $3 million in life insurance proceeds, even if those proceeds were intended to redeem a portion of the seller\u2019s own shares<\/em>.\u201d Only accepting $3.86 million, the court continued, would be to ignore the anticipated life insurance proceeds.<\/p>\n

Finally, the court considered another thought experiment. To value the company without the life insurance proceeds, each share would be worth $7,720 before the redemption. But, after the redemption and the redeemed interest is extinguished, the shares would be about $33,800 each, representing full control of the company. Thus, \u201c[o]vernight and without any material change to the company, [the surviving brother\u2019s] shares would have quadrupled in value.\u201d<\/p>\n

In sum, the court determined that \u201c[t]he proceeds were simply an asset that increased shareholders\u2019 equity. A fair market value of [the deceased brother\u2019s] shares must account for that reality.\u201d<\/p>\n

In reaching this decision, the court disagreed with the Eleventh Circuit\u2019s decision in Estate of Blount v. Comm\u2019r<\/em>, 428 F.3d 1338 (11th Cir. 2005), which held that corporate insurance proceeds to fund an obligatory purchase obligation were offset by that liability and therefore need not be included in the company\u2019s value.<\/p>\n

The case is Connelly v. United States<\/em>, No. 21-3683 (8th Cir. June 2, 2023). You can read the case here.<\/p>\n

This is only a summary of the case and some portions\u2014including facts, issues, or analysis\u2014may have been omitted or edited; if you need advice in this area, please review the case in its entirety and consult an attorney.<\/em><\/p>\n<\/div>\n

Read the full article here<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

A recent case demonstrates the impact that a stock-purchase agreement and life insurance can have (or not have) on the valuation of a closely held company for estate tax purposes. Before diving into the case, some context is helpful. It is not uncommon for closely held businesses to have buy-sell agreements. In many instances, the […]<\/p>\n","protected":false},"author":1,"featured_media":3117,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"content-type":"","footnotes":""},"categories":[79],"tags":[],"class_list":{"0":"post-3116","1":"post","2":"type-post","3":"status-publish","4":"format-standard","5":"has-post-thumbnail","7":"category-tax-preparation"},"yoast_head":"\n8th Circuit Includes Insurance Proceeds For Redemption In Estate Tax Valuation Of Closely Held Company | Brandiary<\/title>\n<meta name=\"description\" content=\"A recent case demonstrates the impact that a stock-purchase agreement and life insurance can have (or not have) on the valuation of a closely held company\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/mysourcefunding.com\/?p=3116\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta 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