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.

Pierre v. Commissioner, 133 T.C. No. 2 (2009).