Built-In Capital Gains Considered in Build Up of the Marketability Discount

Business Valuation Update BVLaw
Legal and Court Case Update
August 18, 2000
6512 Operators of Nonresidential Buildings
531120 Lessors of Nonresidential Buildings (except Miniwarehouses)
estate and gift taxation
discount rate, net asset value, capitalization rate, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), holding period, build-up method

Borgatello v. Commissioner
T.C. Memo. 2000-264, 2000 Tax Ct. Memo LEXIS 309
Federal Court
United States Tax Court
Wayne Holden (for estate)<br>James Brockardt (for estate)<br>David Marx (for IRS)|Roger Wilde (for IRS)


The Tax Court valued a real estate holding company using the net asset value method.

See Also

Borgatello v. Commissioner