Most importantly, the court ruled that no discount should be applied to the minority interest itself but only to the lack of marketability
of nontraded stock.
Having access to the technology transfer offered by CMI classes, AFS books and technical papers and modern casting makes them more knowledgeable and aware of changing practices, helping to ensure job security and marketability
Further, the willing buyer-willing seller test mandated discounting the IRAs for (1) the income tax liability associated with their distributions and (2) their lack of marketability
. The estate noted that, pursuant to the IRA agreements, the IRAs were nontransferable and, thus, unmarketable.
This is an instance of how architectural design can enhance a building's image and marketability
In this case the taxpayer requested an exception for the annuity's lack of marketability
The principal controversy in this recent case involved the appropriate discount for lack of marketability
(DLOM) related to the subject stock.
The value of a minority interest should reflect two separate and distinct discounts from the value of a 100% interest--a minority interest discount and a discount for lack of marketability
. A majority interest with less than complete control also could have its value affected by discounts resulting from a lack of certain control rights or certain marketability
A's analyses of studies on minority discounts contain some element of discount for lack of marketability
, and these studies result in an overstatement of the minority discount.
Although commercialism and of course, marketability
, are important, the emphasis is on how the space is to be used.
With an IDIT, a grantor can discount assets transferred or sold due to lack of marketability
or a minority interest, reducing their fair market value, the taxable gift and the promissory note.
This present value is an estimate of the value of the mortgage assuming it has the same degree of marketability
as a Ginnie Mae pass-through.
What is marketability
and why does that matter in corrections?