Ludwick v. Commissioner: Loss for the Taxpayer

Ori Bash (attorney, Palo Alto, CA) recently published his article entitled Far-Reaching IRS Victory in Ludwick, Wealth Strategies J., June 16, 2010. 

The introduction is below:

In Ludwick v. Comm’r, TC Memo 2010-104, the Service struck a major blow for its favored approach to undivided interests, not only winning acceptance of its “cost to partition” approach, but winning the argument on most of the important inputs to the model, yielding a discount that’s a fraction of what has been taken in similar cases in the past. Ludwick is a troubling departure from past valuation cases and represents a significant loss for the taxpayer.

Special thanks to Matthew Engler (J.D. Candidate 2012, The George Washington University Law School) for bringing this to my attention.