Fractional Interest and Blockage Discount Considered

Business Valuation Update BVLaw
Legal and Court Case Update
December 29, 1999
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
Federal Court
United States Tax Court
Paul Talmage (for estate)<br>Karen Ann Simmons (for IRS)


The Tax Court considered the size of discounts for blockage and fractional interests on nine rental properties.

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.