Louisiana Appeals Court Affirms Use of Discounts in LLC Valuations

BVLaw
Court Case Digests
June 27, 2018
8011 Offices and Clinics of Doctors of Medicine
621493 Freestanding Ambulatory Surgical and Emergency Centers
buy/sell agreement
discount for lack of control (DLOC), expert testimony, income approach, closely held corporation, discount for lack of marketability (DLOM), fair market value (FMV), market approach, minority discount, minority interest, book value, operating agreement

Wall v. Bryan
2018 La. App. LEXIS 1257
US
State Court
Louisiana
Court of Appeal
Benjamin C. Woods (plaintiff); Stuart Neiberg (defendants)
Stephens

Summary

Appeals court supports trial court’s decision to value departing member’s minority interest on fair market value basis pursuant to state statute rather than method specified in some existing corporate documents; appeals court affirms lower court’s discretion to apply post-Cannon discounts.

See Also

Wall v. Bryan

Appeals court supports trial court’s decision to value departing member’s minority interest on fair market value basis pursuant to state statute rather than method specified in some existing corporate documents; appeals court affirms lower court’s discretion to apply post-Cannon discounts.