A New Guideline for Identifying Active vs. Passive Business Appreciation?
Efforts to lock in value for buy-sell purposes often fail
Report is inadmissible unless expert is certified, uses correct methodology, and does independent analysis
Failure to challenge distinction between personal and professional goodwill leads to affirmation for opposing valuation
11th Circuit affirms that estate tax value cannot be set by changeable buy-sell agreement, but insurance proceeds used for buyout not included in value
