Discounting majority interests – Tax Court tackles valuation of real estate LLCs

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Abstract: A recent U.S. Tax Court case addressed the valuation of majority interests in five real estate holding companies for estate tax purposes. This article summarizes how the court in Estate of Warne addressed the issue of valuation discounts for majority interests held by the estate and for fractional interests donated to charity. A sidebar explains how failure to consider external market conditions can be a potential pitfall when calculating economic damages. Estate of Miriam M. Warne, T.C. Memo. 2021-17 (February 18, 2021).