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Valuation and Planning Lessons From Smaldino

Tax Court applies IRC Section 2701 special valuation rules.

The recent Tax Court decision in Smaldino v. Commissioner1 provides important lessons regarding the valuation of gifts of discounted interests in a family limited partnership. In that case, Louis P. Smaldino placed 10 rental properties in Southern California in Smaldino Investments, LLC  (Smaldino Investments) in late 2012. The entity was owned through Louis’ revocable trust. A few months later, in April 2013, he transferred effectively a 49% interest in Smaldino

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