A Faulty Reading

In the case of Holman v. Commissioner,1 the U.S. Court of Appeals for the Eighth Circuit upheld a Tax Court decision2 that a discount for lack of marketability (DLOM) of 12.5 percent was appropriate for a private investment company holding only Dell common stock. I believe that the evidence presented to the court to support this theory is inaccurate and that the evidence may have been incomplete.

In the case of Holman v. Commissioner,1 the U.S. Court of Appeals for the Eighth Circuit upheld a Tax Court decision2 that a discount for lack of marketability (DLOM) of 12.5 percent was appropriate for a private investment company holding only Dell common stock. I believe that the evidence presented to the court to support this theory is inaccurate and that the evidence may have been incomplete. The court based the DLOM amount on a natural limit or a cap. An expe

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TAGS: Research
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