Peracchio v. Commissioner

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September 25, 2003

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6733 Trusts, Except Educational, Religious, and Charitable
525920 Trusts, Estates, and Agency Accounts
estate and gift taxation
family limited partnership (FLP), restricted stock study, discount for lack of marketability (DLOM), fair market value (FMV), gift tax, real estate investment trusts (REIT), guideline companies, mandelbaum factors, discount for lack of control (DLOC)
Peracchio v. Commissioner
T.C. Memo 2003-280
US
Federal Court
United States Tax Court
Timothy R. Dankoff, ASA (for taxpayer); Charles H. Stryker (for taxpayer); Francis X. Burns (for IRS)
Halpern

Summary

Issues were appropriate discount for lack of control and discount for lack of marketability to apply in valuing gifts of family limited partnership interests.
Peracchio v. Commissioner
PDF, Size: 38 KB

See Also

Tax Court displeased with all experts’ DLOC and DLOM analyses

Legal and Court Case Update
November 2003

The primary issues in this gift tax case were the appropriate discounts for lack of control and lack of marketability to apply to gifted and sold interests of a family limited partnership.