Tax Court Upholds Estate's Fractional Discount for Minority Interest Held by Limited Partnership

Business Valuation UpdateVol. 7 No. 6
Legal and Court Case Update
June 2001
0191 General Farms, Primarily Crop
111998 All Other Miscellaneous Crop Farming
estate and gift taxation
estate tax, fair market value (FMV), sole proprietorship, limited partnership, marketability

Estate of Forbes v. Commissioner
T.C. Memo 2001-72, 2001 Tax Ct. Memo LEXIS 94
March 23, 2001
US
Federal Court
United States Tax Court
James F. Lawton (for estate)<br>Glen A. Hultquist (for estate)<br>Richard Parks (for IRS)
Thornton

Summary

This valuation dispute arose from the undivided real estate interest held by the Forbes QTIP trust.

See Also

Estate of Forbes v. Commissioner

Issue is fair market value of 42% and 42.9% undivided interests in two real estate parcels held by the QTIP, and what fractional discount should apply.