Court rejects value based on improbable subsequent events
$225.00
Description
Abstract: In a recent gift tax case, the U.S. Tax Court rejected the IRS’s valuation of a nonvoting stake in a limited liability company (LLC), because it was based on actions conjectured to occur after the gift was made that weren’t reasonably probable. This article explains why the court accepted the taxpayer’s value, which included discounts for lack of control and marketability. Grieve v. Commissioner, TC Memo 2020-28 (March 2, 2020)
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