Blockage Discount Appropriate for Apartment House

Business Valuation UpdateVol. 6 No. 4
Legal and Court Case Update
April 2000
6513 Operators of Apartment Buildings
531110 Lessors of Residential Buildings and Dwellings
estate and gift taxation
discount rate, estate tax, fractional interest

Estate of Brocato v. Commissioner
T.C. Memo 1999-424, 1999 Tax Ct. Memo LEXIS 481
December 29, 1999
Federal Court
United States Tax Court
Paul Talmage (for estate)<br>Karen Ann Simmons (for IRS)


The taxpayer was granted a 20% fractional interest discount and an 11% blockage discount with apartment house properties, based on comparable sales and an analysis of market conditions and the economy.

See Also

Estate of Brocato v. Commissioner

At issue is whether respondent is equitably estopped from assessing additional estate tax, and if not, the proper amount of blockage and fractional interest discounts to be applied to petitioner’s nine real properties must be determined.