Court Says Reduced Minority Discount Appropriate Where Minority Interest Has Elements of Control

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Court Case Digests
June 10, 2020

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6719 Offices of Holding Companies, NEC
551112 Offices of Other Holding Companies
estate and gift taxation, federal taxation
discount for lack of control (DLOC), estate and gift tax, expert testimony, closely held corporation, discount for lack of marketability (DLOM), fair market value (FMV), minority discount, minority interest, controlling interest
Nelson v. Commissioner
T.C. Memo 2020-81
US
Federal Court
Federal
United States Tax Court
Roy Shrode, Barbara Rayner (taxpayers/petitioners); Mark Mitchell (IRS/respondent)
Pugh

Summary

In gift tax case, Tax Court finds donor transferred percentages in limited liability company rather than fixed dollar amounts based on language in transfer instruments; further, where transferred minority interests include elements of control, minority discount should be reduced, not eliminated.

See Also

Nelson v. Commissioner

Full Text of Court Cases
June 10, 2020

In gift tax case, Tax Court finds donor transferred percentages in limited liability company rather than fixed dollar amounts based on language in transfer instruments; further, where transferred minority interests include elements of control, minority discount should be reduced, not eliminated.

This article also appears in:
Business Valuation UpdateVol. 26 No. 9