Option With No Bona Fide Business Purpose Not Relevant to FMV

Business Valuation UpdateVol. 6 No. 8
Legal and Court Case Update
August 2000
8059 Nursing and Personal Care Facilities, NEC
623110 Nursing Care Facilities (Skilled Nursing Facilities)
estate and gift taxation
income approach, net asset value, capitalization rate, estate tax, fair market value (FMV), discount for lack of control (DLOC)

Estate of Godley v. Commissioner (I)
T.C. Memo. 2000-242, 2000 Tax Ct. Memo LEXIS 284
August 4, 2000
Federal Court
United States Tax Court
Mitchell Kaye, Robert O. Beck III, David A. Dvorak, and Tom J. Keith David A. Dvorak,Tom J. Keith and David Archer (for defendant)


This case deals with the valuation for estate tax purposes of four Housing and Urban Development (HUD) housing partnerships and one real estate management partnership.

See Also

Estate of Godley v. Commissioner (I)

At issue in the equitable distribution litigation was the value of Fred Jr.'s 50-percent general partnership interest in the partnerships.