Tax Court Allows Capital Gains Discount for Real Estate Holding Company

Business Valuation Update BVLaw
Legal and Court Case Update
August 18, 2000

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6512 Operators of Nonresidential Buildings
531120 Lessors of Nonresidential Buildings (except Miniwarehouses)
estate and gift taxation
discount rate, net asset value, capitalization rate, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), holding period, build-up method
Borgatello v. Commissioner
T.C. Memo. 2000-264, 2000 Tax Ct. Memo LEXIS 309
US
Federal Court
United States Tax Court
Wayne Holden (for estate)<br>James Brockardt (for estate)<br>David Marx (for IRS)|Roger Wilde (for IRS)
Wells

Summary

The issue in this estate tax matter is the fair market value of decedent's 82.76% interest in Valley Improvement Co. Inc. (VIC), a real estate holding company, as of Jan. 12, 1994.

See Also

Borgatello v. Commissioner

Full Text of Court Cases
August 18, 2000