Disregarded But Not Forgotten

Is the transfer of an interest in a single-member limited liability company (LLC) a disregarded entity valued as a transfer of a proportionate share of the underlying assets owned by the LLC or as a transfer of an interest in the LLC subject to valuation discounts for lack of marketability and control? According to a recent en banc Tax Court decision, Pierre v. Commissioner,1 a disregarded entity

Is the transfer of an interest in a single-member limited liability company (LLC) — a “disregarded entity” — valued as a transfer of a proportionate share of the underlying assets owned by the LLC or as a transfer of an interest in the LLC subject to valuation discounts for lack of marketability and control? According to a recent en banc Tax Court decision, Pierre v. Commissioner,1 a disregarded entity is not to be forgotten.

The taxpayer, Suzanne Pierre, received a

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