Tax Court Rejects IRS’ Value Analysis, Finding It Assumes Additional Actions Not ‘Reasonably Probable’

BVLaw
Court Case Digests
March 2, 2020

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6719 Offices of Holding Companies, NEC
551112 Offices of Other Holding Companies
estate and gift taxation
discount for lack of control (DLOC), discount rate, expert testimony, discount for lack of marketability (DLOM), estate & gift, fair market value (FMV), limited liability company, estate planning
Grieve v. Commissioner
T.C. Memo 2020-28
US
Federal Court
Federal
United States Tax Court
Value Consulting Group (petitioner, tax return appraisal); Will Frazier (petitioner, Tax Court); Mark Mitchell (IRS, Tax Court)
Kerrigan

Summary

In gift tax dispute, Tax Court rejects IRS expert’s valuation of noncontrolling, nonmarketable interests in two LLCs; expert proposed valuation theory and method were intended to lower opposing experts’ minority and marketability discounts but lacked support in facts, case law, or among peers.

See Also

Grieve v. Commissioner

Full Text of Court Cases
March 2, 2020

In gift tax dispute, Tax Court rejects IRS expert’s valuation of noncontrolling, nonmarketable interests in two LLCs; expert proposed valuation theory and method were intended to lower opposing experts’ minority and marketability discounts but lacked support in facts, case law, or among peers.

This article also appears in:
Business Valuation UpdateVol. 26 No. 5