High Court Says Context Supports Use of Discounts in Buyout From Shareholder Oppression

BVLaw
Court Case Digests
May 12, 2020
1771 Concrete Work
238110 Poured Concrete Foundation and Structure Contractors
judicial dissolution
expert testimony, fair value, breach of fiduciary duty, buyout, closely held corporation, discount for lack of marketability (DLOM), fair market value (FMV), minority discount, minority interest, minority oppression, discount for lack of control (DLOC)

Robinson v. Langenbach
2020 Mo. LEXIS 192
US
State Court
Missouri
Supreme Court of Missouri
Christopher King (plaintiff); Michael Probst (defendants)
Stith (en banc opinion)

Summary

State high court upholds trial court’s use of DLOM and minority discount in buyout of minority interest resulting from shareholder oppression; court says there is no “fixed set of factors” trial court must consider for fair value calculation; “context is crucial” and here justified discounts.

See Also

Robinson v. Langenbach

State high court upholds trial court’s use of DLOM and minority discount in buyout of minority interest resulting from shareholder oppression; court says there is no “fixed set of factors” trial court must consider for fair value calculation; “context is crucial” and here justified discounts.

This article also appears in:
Business Valuation UpdateVol. 26 No. 8