Grieve v. Commissioner

BVLaw
Full Text of Court Cases
March 2, 2020

Access the Full Article

This article and its downloads are available with a subscription to any of these products:
Already a subscriber?  Login
This article is also available for purchase. (7,276 words)   Add to Cart >>
Need help? Contact us:
1-503-479-8200 ext 2 or sales@bvresources.com
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.
Grieve v. Commissioner
PDF, Size: 136 KB

See Also

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

Court Case Digests
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.