LLC valuation case is a win for the taxpayer.

• Author: Sherr, Eileen
• Position: News Notes

In a win for the taxpayer in a limited liability company (LLC) valuation case (W.G. Anderson et al., WD AL., 2/22/06), a U.S. District Court held that the IRS erred in revaluing a decedent's minority ownership interest in four LLCs. The estate will now receive a tax refund for the estate and gift taxes, related interest and properly deductible administrative expenses. The estate did not win on its claim for attorneys' fees and litigation costs, because the gross value of the estate at the decedent's death was greater than $2 million. In determining the fair market value of the decedents interest in her directly held property and minority interest in the LLCs, the court found a 40% marketability...