Victory for Taxpayer in U.S. District Court
Expert testimony by HFBE's Donald Barker in the Estate of Murphy v. The United States of America found to be more credible than IRS Appraiser.
* The Estate filed suit seeking a refund of approximately $41 million of estate taxes and interest assessed by the IRS.
* The issues pending before the Court included the fair market value of the Estate’s 95.25365 percent limited partner interest in the Charles H. Murphy Family Investments Limited Partnership and a 49 percent member interest in Murphy Family Management, LLC.
* The partnership owned marketable securities, including sizable positions in Murphy Oil, Deltic Timber, BancorpSouth, timber and farm land.
* During the trial, the parties’ valuation experts, Donald Barker (taxpayer) and Francis Burns (IRS), testified as to the fair market value of the LP and LLC interests held by the Estate.
* Both experts applied certain valuation discounts, including discounts for Rule 144/blockage, lack of control, and lack of marketability.
* The appropriate size of the discounts was in dispute.
In each instance, “the Court finds Barker’s valuation analysis more credible than Burns’ analysis,” and concludes that the discounts determined by Donald Barker are appropriate.
10/09/09
Download: Murphy_Opinion.pdf
Download: Murphy_Summary_of_Discounts.jpg
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