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- Title
A Comprehensive Analysis of Minority Interest Discounts in Estate and Gift Taxation.
- Authors
Woodruff, Gregg S.; Langstraat, Craig J.; Malloy, John M.
- Abstract
One of the most litigated and adjusted areas in taxation has been the determination of the minority interest discount in estate and gift taxation. Valuation disputes arise because the valuation processes for estate and gift taxation are "inherently imprecise," and the goals of the taxpayer and Internal Revenue Service (IRS) are diametrically opposed. The IRS's vigorous defense of the estate and gift tax base and the taxpayers' attempts to pay no more tax than is their legal duty have resulted in a history of situations where the taxpayer and the IRS turn to the courts for adjudication. This paper addresses the basis for a minority interest discount, the determination whether ownership interests are in fact minority interests, and the importance of facts and law in the determination of the minority interest discount. A comprehensive analysis of estate and gift tax cases that determined minority interest discounts is used as a basis for planning ideas to maximize these discounts.
- Subjects
TAX laws; TAX planning; GIFT taxes; TAX assessment; UNITED States. Internal Revenue Service; INTEREST rates
- Publication
ATA Journal of Legal Tax Research, 2006, Vol 4, p117
- ISSN
1543-866X
- Publication type
Academic Journal
- DOI
10.2308/jltr.2006.4.1.117