The Five Marketability Forces Framework

The Five Marketability Forces Framework

An approach to business valuations of non-controlling interests in privately held companies

The majority of disputes that arise from the audit of gift tax returns and estate tax returns are related to the selection of marketability discounts, commonly known as the discount for lack of marketability (DLOM). Case precedent, as well as the Internal Revenue Service, continue to challenge DLOM conclusions that are made without some subject company and subject interest customized analysis. These analyses will likely be subject to greater scrutiny and audit.

The valuation com

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