4th Circuit Upholds No Minority Discount for 50% Interest in HUD Partnerships

Business Valuation UpdateVol. 8 No. 6
Legal and Court Case Update
June 2002
9531 Administration of Housing Programs
925110 Administration of Housing Programs
estate and gift taxation
estate tax, internal revenue service (IRS)

Estate of Godley v. Commissioner (II)
286 F.3d 210, 2002 U.S. App. LEXIS 6856
April 15, 2002
Federal Court
4th Circuit
United States Court of Appeals
Mitchell Kaye (for IRS)


At the time of his death, decedent owned a 50% interest in five general partnerships.

See Also

Estate of Godley v. Commissioner (II)

Estate argued that the question of whether decedents fifty percent interest represented a lack of control was a question of law. The Court of Appeals flatly disagreed.