For what it’s worth: Valuation in the courts – FLP discounts and the multitiered company

Description

Abstract: In this issue’s “For what it’s worth: Valuation in the courts,” we look at the long contentious issue of family limited partnerships (FLPs). Gifts of FLP interests allow individuals to transfer wealth at often substantial discounts from the FLP’s underlying net asset value. And this recent Tax Court case provides insight into how the court handles discounts for lack of control and marketability — especially when multiple owners are involved. Citations:  Astleford v. Commissioner, T.C. Memo 2008-128, May 5, 2008.