It’s been well-established for decades that discounts in valuation for federal estate tax and federal gift tax purposes could be claimed on corporate stock (and partnership interests) for minority interest and non-marketability.1 And it has been clear for nearly two decades that discounts could be claimed for co-ownership interests as well.2 Moreover, for nearly a decade, in valuing corporate stock, courts have allowed a discount for potential income tax liability.3
Harl, Neil E.
"Federal Estate Tax Discounts for Potential Income Tax Liability for Retirement Accounts?,"
Agricultural Law Digest: Vol. 17
, Article 1.
Available at: https://lib.dr.iastate.edu/aglawdigest/vol17/iss14/1