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Such Dear Perfection?

Grieve v. Commissioner rejects novel valuation theory.

When valuing a non-controlling, minority interest in an entity for tax purposes, both the government and taxpayers generally agree that significant discounts must apply. But, what if the non-controlling interest being valued isn’t a minority interest? In limited partnerships and limited liability companies, the majority interest (for example, 75% of the entity) can easily be divorced from control by making the minority the general partner or managing member. 


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