The only issue on appeal was the appropriate built-in gains tax discount to be applied in calculating the fair market value of a 62.96% block of common stock.
5th Circuit Orders Dollar-for-Dollar Reduction for Built-In Capital Gains in Asset-Based Valuation
This case comes on appeal to the 5th Circuit Court of Appeals from Estate of Dunn v. Commissioner , T.C. Memo 2000-12, 79 T.C.M. (CCH) 1337 (Jan. 12, 2000), which was abstracted in the March 2000 issue of the Business Valuation Update.