Third Circuit addresses burden of proof in valuing intangibles.
The Tax Adviser › Vol. 37 Nbr. 3, March 2006
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Third Circuit addresses burden of proof in valuing intangibles.
In Capital Blue Cross, 3d Cir., 12/5/05, rev'g in part and remd'g 122 TC 224 (2004), the Third Circuit held that the Tax Court erred in assigning a zero basis in hundreds of terminated insurance contracts issued by Capital Blue Cross (Capital).The appellate court concluded that minor flaws in a taxpayer's valuation were insufficient to reject the val...
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