Court Rejects Expert’s Regression Equation to Determine DLOM

Business Valuation UpdateVol. 19 No. 12
Legal and Court Case Update
December 2013
5962 Automatic Merchandising Machine Operator
454210 Vending Machine Operators
estate and gift taxation
control premium, regression analysis, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), discount for lack of control (DLOC), estate and trusts, generation-skipping transfer tax

Estate of Koons v. Commissioner
2013 Tax Ct. Memo LEXIS 98
April 8, 2013
US
Federal Court
Federal
United States Tax Court
Mukesh Bajaj (petitioners); Francis X. Burns (respondent)
Morrison

Summary

In determining the fair market value of a revocable trust’s interest in an LLC, the Tax Court adopts the IRS expert’s marketability discount and valuation; he rightly assumed it was reasonably foreseeable at the time of the decedent’s death that the trust ...

See Also

Estate of Koons v. Commissioner

In determining the fair market value of a revocable trust’s interest in an LLC, the Tax Court adopts the IRS expert’s marketability discount and valuation; he rightly assumed it was reasonably foreseeable at the time of the decedent’s death that the trust ...