FLP Valuation in the U.S. Tax Court

The valuation of limited partnership (LP) interests in family limited partnerships (FLPs) is a subject that’s been written about extensively for over 30 years. Most of the literary record has been directed at the topic of applicable discounts. In this vein, the discount for lack of marketability (DLOM) has been discussed repeatedly—some might even say ad nauseam. After 30 years of discourse in the literature, countless seminars and webinars and numerous U.S. Tax Court cases, one would think