Valuation of intangibles in relation to the merger of KT Corp (owned by the parents) and CS Corp (owned by their three sons).

In valuing the two companies for the purposes of the merger they incorrectly assumed that CS Corp owned Intangibles that were in fact owned by KT Corp.

The Tax Court found, that the valuation of the intangibles reasonably determined the fair market value, and concluded that gifts totaling $22.8 million was transfered to the three sons on December 31, 1995.