It turns out that yesterday was a bad day for the IRS. Not only did they lose an important gift tax valuation case, but they also lost a very large Family Limited Partnership case in Federal District Court.
I do not think that the facts of Keller vs. United States are very interesting, but the amount sure is. The plaintiff’s initial claim for refund was $40,455,332!! The final amount hasn’t been settled yet, but if anything, it’s going to be even larger than that.