Estate of Stevens v. Commissioner

Full Text of Court Cases
February 18, 2000
6552 Land Subdividers and Developers, Except Cemeteries
237210 Land Subdivision
estate and gift taxation
discount rate, expert testimony, discounted cash flow (DCF), fair market value (FMV), valuation methods, fractional interest, fractionalization discount, real property, lease, income capitalization

Estate of Stevens v. Commissioner
T.C. Memo 2000-53
Federal Court
United States Tax Court
Norman C. Hulberg, Morgan W. White (petitioner/ estate); John A. Thomson (respondent/IRS)


In valuing 50% undivided interest in three commercial real properties, Tax Court rejects limiting discounts to costs of partitioning, finding 25% discount is appropriate for all properties and is in line with factor analysis for fractional interests.
Estate of Stevens v. Commissioner
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