Minority Share Gifts: Court Finds 30% Discount for Lack of Marketability

Business Valuation UpdateVol. 1 No. 1
Legal and Court Case Update
October 1995
5621 Women's Clothing Stores
448120 Women's Clothing Stores
estate and gift taxation
restricted stock study, discount for lack of marketability (DLOM), gift tax, initial public offering (IPO)

Mandelbaum v. Commissioner
T.C. Memo 1995-255
June 12, 1995
Federal Court
United States Tax Court
Paul R. Mallarkey (for respondent) Roger J. Grabowski (for petitioner)


The parties stipulated to freely traded minority interest values, so the only issue was the discount for lack of marketability.

See Also

Mandelbaum v. Commissioner

At issue is the amount of discount for lack of marketability that should be applied to determine the fair market value of certain shares of stock owned by some or all of petitioners.