Estate of Murphy v. United States, U.S. Dist. Ct. W.D. Ark.,
In Murphy v. U.S (2009), the court also upheld substantial discounts to the decedent’s interests. The decedent’s interest in the FLP at death consisted of an approximately 95% limited partner interest and a 49% interest in an LLC that owned the approximately 2.3% general partnership interest. The court upheld a combined control and marketability discount of 41% for the 95% limited partnership interest. Also, the court allowed tiered discounts in valuing the decedent’s 49% interest in the LLC that owned the 2.3% general partnership interest. The overall discount for the LLC interest was 52%.