Since the enactment of Internal Revenue Code Section 2703, the U.S. court system and the business valuation community have debated the meaning of that section and how it applies to estate and gift tax valuations. Increasingly, the government is using IRC Section 2703 to challenge specific provisions within agreements — including limited partnership (LP) agreements — that taxpayers claim restrict value and justify larger valuation discounts.
To date, case law regarding Section 2703 and
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