Transfers are valued as transfers of interests in a limited liability company so that the LLC is not disregarded under the “check the box” regulations to treat the transfers as transfers of a proportionate share of assets owned by the LLC. As a result, the transfers are subject to valuation discounts for lack of control and lack of marketability.
Monday, October 19, 2009
Tax Court Rules on LLC Transfer Valuation
Transfers are valued as transfers of interests in a limited liability company so that the LLC is not disregarded under the “check the box” regulations to treat the transfers as transfers of a proportionate share of assets owned by the LLC. As a result, the transfers are subject to valuation discounts for lack of control and lack of marketability.