Built-In Capital Gains Liability of Small Minority Interest Should Be Discounted to Reflect Time Value of Money

Business Valuation UpdateVol. 11 No. 8
Legal and Court Case Update
August 2005
estate and gift taxation
income approach, asset approach, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), arm's length, discount for lack of control (DLOC)

Estate of Jelke v. Commissioner (I)
T.C. Memo 2005-131, 2005 Tax Ct. Memo LEXIS 128
May 31, 2005
US
Federal Court
United States Tax Court
Veronica Vilarchao
William Frazier (for estate)<br>Israel Shaked (for IRS)
Gerber

Summary

The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value and the appropriate discounts for lack of marketability and control.

See Also

Estate of Jelke v. Commissioner (I)

The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value, and the appropriate discounts for lack of marketability and control.