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Lack of marketability and minority discounts for closely-held stocks

Article Abstract:

Economic analysis of the methods used to discount the valuation of closely-held stock for tax purposes demonstrates that many factors can influence discounts for minority ownership and lack of marketability. Courts considering valuation discounts must consider whether the certain factors, such as low profitability, have already been incorporated into the stock's value. Extraneous factors may compromise the value of empirical data, and firm size may influence valuation as well.

Author: Paulsen, Jon
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1996
Close corporations, Closely held corporations, Minority stockholders

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The new paradigm: life after the elimination of valuation discounts

Article Abstract:

Tax Court cases and IRS pronouncements regarding real property undivided interest discounts will become more relevant if President Clinton's Feb 3, 1998 proposal to disallow all other valuation discounts is adopted. The disallowance would be for those entities with readily marketable assets for purposes of estate or gift tax. The Tax Court has rejected the strict IRS position that valuation should be determined by partition cost.

Author: Hall, Lance
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
Business enterprises, Real property, Real estate appraisal

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Life after Davis Est.: valuation discounts for built-in capital gains tax liabilities

Article Abstract:

This article presents a discussion of cases relevant to valuation discount determinations of built-in capital gains tax liabilities with a focus upon the Tax Court's favorable decision in Estate of Davis. Analysis of the case law demonstrates that reductions in transfer taxes are possible for stockholders of C corporations holding appreciated property.

Author: Hoffmann, Carsten
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1999
United States, Tax Law, Public Finance Activities, Liabilities (Accounting), Taxation, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

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Subjects list: United States, Laws, regulations and rules, Valuation, Discount (Finance)
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