Hypothetical Partition Discount Is Insufficient for Fractionalized, Noncontrolling Interests

Business Valuation UpdateVol. 11 No. 9
Legal and Court Case Update
September 2005
estate and gift taxation
estate tax, fair market value (FMV), fractionalization discount

Estate of Baird v. Commissioner
2005 U.S. App. LEXIS 13905
July 11, 2005
US
Federal Court
5th Circuit
United States Court of Appeals
James A. Young (for estates)<br>Lewis C. Peters (for estates)<br>James C. Steele, III. (for estates)<br>Francis X. Burns (for IRS)
Jolly

Summary

In this estate tax case, the issue was whether the IRS' position in applying discounts to fractional, noncontrolling interests in timberland was justified for purposes of determining whether taxpayers were entitled to administrative and litigation costs.

See Also

Estate of Baird v. Commissioner

In this estate tax case, the issue was whether the IRS's position in applying discounts to fractional, non-controlling interests in timberland was justified.