EFTA01459107

Court relied on the price of the shares determined in the Final Decree. In regards to any penalties for not declaring a gift, participants from the firm that provided accounting services for Sumner and NAI some 40 plus years ago, testified about uncertain memories and vague discussions with now deceased partners. A key memory, however, was the fact that one of the accountants recalled that a now deceased senior partner had told Sumner that there was no need to file a gift tax return because of the Final Decree. Since Sumner was relying on the advice of competent professionals, no penalties were added. Somewhere, Edward is smiling. W T.C. Memo. 2015-237 (December 9, 2015) * Mr. Hall is a Managing Director of FMV Opinions. Inc., a national valuation and investment banking firm with offices in New York, San Francisco, Irvine, and Dallas. Mr. Hall heads up FMV's estate and gift tax valuation practice. He may be reached at lhallAfmv.com. Additional information regarding FMV Opinions, Inc. can be accessed at www.fmv,com. 2 145 T.C. No. I I (October 26, 2015) 3 This section comes from my prior article regarding the Edward Redstone v. Commissioner case 4 Today, NAI is the owner of many companies, including Viacom, and is run by Edward's brother, Sumner O'Connor V Redstone - 896 N.E.2d 595 (Mass. 2008) rev 2015 FMV Opinions, Inc. I !wit. ',I Lc wa adored m FalVard The INV Viltuiten Plmsc do rot roµsd to Jli, tri l All quensont and colas ten be It& t mud to otiattinn' con To vanbernbt, aeply to is. mud welt 'unsulnatu' men ethane ot amply dick on the bleranti/ottbp 'Thu ts not attended or wntc.. to be used. and canna ho ;sod by any taxpayer or *Avner to • taxpayer, for the pews* of evading penalties dun may be imposed upon the tamtayer or ahem by the IRS. No is this mama legal *done and it should rut In orattneel a such' FMV Opinions, Inc 3333 Michelson Drive, Suite 900 Irvine. CA 92612 New York - San Francisco - Irvine - Dallas This e-mail was sent by FMV Opinions. Ing.. locatal at 333? Nficbekon Drive, Suite 900, Irvine, CA 92612 (USA? To motive no further e-mails. plume stick him or reply to this c-mail with "unliir in the StitijoS This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0119341 CONFIDENTIAL SONY GM_00265525 EFTA01459107