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I remember when those who worked on the institutional side of Wall Street walked with swagger. Investment bankers, sales traders, bond salesmen — the whole lot of ‘em — used to look down on the retail stock broker, er, financial advisor. Retail...
In the case of Holman v. Commissioner,1 the U.S. Court of Appeals for the Eighth Circuit upheld a Tax Court decision2 that a discount for lack of marketability (DLOM) of 12.5 percent was appropriate for a private investment company holding only...
The subject of tiered discounts is a controversial one. Taxpayers may view the application of a tiered discount as a means to achieve a better tax result. Those who are already critical of valuation discounts see the additional layer of discounts...
Since the enactment of Internal Revenue Code Section 2703, the U.S. court system and the business valuation community have debated the meaning of that section and how it applies to estate and gift tax valuations. Increasingly, the government is...
