Frederick's of Hollywood Stock Not Aggregated for Valuation; 25% Blockage Discount Applied

Business Valuation UpdateVol. 5 No. 6
Legal and Court Case Update
June 1999
5632 Women's Accessory and Specialty Stores
448190 Other Clothing Stores
estate and gift taxation
fair market value (FMV)

Estate of Mellinger v. Commissioner of Internal Revenue
112 T.C. 26, 112 T.C. No. 4, 1999 U.S. Tax Ct. LEXIS 4
January 26, 1999
Federal Court
United States Tax Court
Curtis R. Kimball (for estate)<br>Ira M. Cotler (for estate)<br>David N. Fuller (for IRS)


Decedent, the widow of Frederick N. Mellinger, held Frederick's of Hollywood stock in three capacities: (1) as income beneficiary of a QTIP irrevocable marital trust her predeceased husband established under IRC § 2056(b)(7); (2) as beneficiary of a revocable trust that she established herself; and (3) 50 shares outright.

See Also

Estate of Mellinger v. Commissioner of Internal Revenue

At issue is the valuation of the decedent's stock at death.