Tax Law | Expert Legal Commentary
July 13, 2010
Holman v. CIR: Valuation of Gifted LLP Shares
Holman v. Commissioner of Internal Revenue
By
H. Jacob Lager of Zuber & Taillieu LLP
The Eighth Circuit U.S. Court of Appeals recently ordered that I.R.C. section 2703 could be applied to disregard transfer restrictions for valuations of gifts of shares in a family limited partnership (“FLP”). In Holman v. Commissioner of Internal Revenue, 601 F.3d 763 (8th Cir., 2010), the 8th Circuit also agreed with the tax commissioner that, while lack of control and marketability discounts would apply to the gifts of the FLP units, the discounts should be lower than those proposed by the donors.
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About the Author
H. Jacob Lager is a Partner of Zuber & Taillieu LLP, focusing on tax law.
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