The Appropriateness of Applying Multi-Level Discounts for Tiered Entities.

James G. Robe (Portland, Oregon) has published his article entitled Multi-Level Discounts for Tiered Entities–Insights from Historical Case Law, 35 Am. C of Trust and Estate Counsel J. 137 (2009). 

The introduction of the article is below:

How successful have taxpayers been in applying multi-level discounts (e.g. discounts for lack of control and lack of marketability) for tiered entities–holding companies that own an interest in another holding company?  The Tax Court, as well as other courts, have opined on the appropriateness of applying multi-level discounts for tiered entities.  This article presents an over of 11 court cases that have dealt with valuation of tiered entities.  Astleford, Dean, Galun, Gos, Hjersted, Kosman, Piper, and Whittemore allowed multi-level discounts; and Janda and O’Connell disallowed multi-level discounts. . . .

The rationale outlined by the courts in these cases provides insights regarding the appropriateness of applying multi-level discounts for tiered entities.