Estate of Litchfield v. Commissioner (United States Tax Court)
In the Estate of Litchfield v. Commissioner, T.C. Memo 2009-21, the U.S. Tax Court considered the appropriate built-in gains tax, lack of marketability and minority interest discounts that were applied to two family-owned companies which owned real estate and marketable securities. The decedent owned a minority interest in both entities. The Tax Court concluded that a 17.4% and a 23.6% discount for built-in gains tax, 11.9% discount for lack of control, and a 25% and 20% discount for lack of marketability were appropriate.