5th Circuit Upholds Tax Court’s Characterization of Interest and Discount Rulings

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Court Case Digests
October 24, 2018

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6282 Investment Advice
523920 Portfolio Management
estate and gift taxation
discount for lack of control (DLOC), expert testimony, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), partnership agreement, limited partnership, mandelbaum factors
Estate of Streightoff v. Commissioner (I)
T.C. Memo 2018-178
US
Federal Court
Federal
United States Tax Court
Juliana Vicelja (IRS); Oliver Warnke, Alan Harp (estate)
Kerrigan

Summary

In estate tax dispute, Tax Court agrees with IRS that decedent transferred limited partner interest, not assignee interest, to revocable trust; under partnership agreement, limited partner had rights not available to assignee; court rejects discount for lack of control and adopts IRS’ DLOM rate.

See Also

Estate of Streightoff v. Commissioner (I)

Full Text of Court Cases
October 24, 2018

In estate tax dispute, Tax Court agrees with IRS that decedent transferred limited partner interest, not assignee interest, to revocable trust; under partnership agreement, limited partner had rights not available to assignee; court rejects discount for lack of control and adopts IRS’ DLOM rate.