Marketability discount may be applied where there is no impending sale but is within court’s discretion
The valuation issues in this marital dissolution were whether a discount for lack of marketability should have been applied to husband’s minority interests in two medical-practice businesses, and whether a buy-sell provision in a third business was determinative of that business's fair market value.
Built-In Capital Gains Liability of Small Minority Interest Should Be Discounted to Reflect Time Value of Money
The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value and the appropriate discounts for lack of marketability and control.
Estate of Jelke v. Commissioner (I)
The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value, and the appropriate discounts for lack of marketability and control.
Fausch v. Fausch
The valuation issues in this marital dissolution were whether a discount for lack of marketability should have been applied to husband's minority interests in two medical-practice businesses, and whether a buy-sell provision in a third business was determ ...
Use of fair market value reasonable even where recipient will obtain control
In this probate case, the court of appeals upheld the district court’s decision to use fair market value rather than ...
Husband’s version of the facts not supported by the record
Husband and wife were married in 1979, and wife filed for divorce in 2000.
Tax Court displeased with all experts’ DLOC and DLOM analyses
The primary issues in this gift tax case were the appropriate discounts for lack of control and lack of marketability to apply to gifted and sold interests of a family limited partnership.
Court Uses Raw Data From Bajaj Study to Determine DLOM
The only issue in this case was the fair market value of gifted family limited partnership (FLP) interests.
Tax Court Determines That Value Was 'Somewhere in the Middle' of Expert Opinions
The taxpayers' expert, Gregory Heebink, used the discounted cash flow (DCF) method and the guideline public company method.
Peracchio v. Commissioner
Issues were appropriate discount for lack of control and discount for lack of marketability to apply in valuing gifts of family limited partnership interests.
Lappo v. Commissioner
The issue for decision is the fair market value of interests in a family limited partnership that petitioner transferred in 1996.
In re Estate of King
Issue is whether discounts for marketability and lack of control should be applied to determine value of minority interest in a closely held corporation.
Hess v. Commissioner
Taxpayers gave 10 shares of HII common stock (a 10% stockholder interest) to an irrevocable trust established for their daughter. Issue was the fair market value of the stock for gift tax p ...
Arn v. Arn
Issue is the valuation of husband's interest in wine company where he originally purchased 20% interest and later purchased remaining 80% but sale was still in escrow.
Gross Estate Includes Date-of-Death Value of Assets Transferred to Family Limited Partnership
The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships: the Thompson Turner Family Limited Partnership ("Turner Partnership") and the Thompson Family Limited Partnership ("Thompson Partnership").
Estate of Thompson v. Commissioner
The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships.
Five reasons for partnership discount
Partnership Re-Sale Discounts Justified , The Partnership Spectrum , January/February 2002, pp. 1-7. Partnership interests trade in the secondary market at discounts mostly due to a lack of mar ...
Marital Court Denies Discounts Based on Shareholder Fair Value Standard
The issues raised in this marital dissolution case were (1) whether the trial court erred in valuing husband's interest in Union County Florist Supplies, Inc . (Florist), the family florist ...
Brown v. Brown
Issues were value husband's interest in the family florist business, whether stock should be discounted for minority interest or marketability, and whether stock was a gift.
Option With No Bona Fide Business Purpose Not Relevant to FMV
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.
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.
Taxpayer Victory on FLP Recognition
On Jan. 18, 2000, Judge Orlando Garcia of the United States District Court ruled in favor of the taxpayer in the first family limited partnership case to be tried in a federal district court.
Church v. United States (I)
At issue is whether a partnership transaction was entered into for no purpose other than to reduce the taxation of Mrs. Church's estate.
Family Limited Partnership Formed Two Days Before Death Not Sham Transaction
The primary issue in this estate tax refund action was whether Stumberg Ranch Partners Ltd. was formed for a bona fide business purpose, or was a sham transaction designed to avoid estate and gift taxes.
No Gift Tax Due When Partnership Was Formed Two Days Before Death
The U.S. District Court for the Western District of Texas rejected the IRS' position that gift tax was due on the formation of a family limited partnership formed two days before the decedent's death.