Such Dear Perfection?Such Dear Perfection?

When valuing a non-controlling, minority interest in an entity for tax purposes, both the government and taxpayers generally agree that significant discounts must apply. But, what if the non-controlling interest being valued isn’t a minority interest? In limited partnerships and limited liability companies, the majority interest (for example, 75% of the entity) can easily be divorced from control by making the minority the general partner or managing member. 

But, what if the interest being valued is an extremely large majority, to the point where it constitutes almost the entirety of the economic interest in the entity? Is that a case for a radically reduced discount? This was the main question recently decided in Grieve v. Commissioner.