Today, discounts for co-ownership of interests in real estate are available generally and that has been the case since the late 1980s.1 Earlier cases involving undivided interests in tenancy in common were not eligible for a discount.2 The Youle case with a 12 ½ percent discount, the first case to allow a discount, was soon followed by discounts of up to 20 percent and, more recently, much larger discounts. For example, the case of Estate of Williams v. Commissioner,3 The discount allowed in that Tax Court decision for a gift of undivided interests in Florida timberland for 20 percent for lack of marketability and 30 percent for lack of control and need to partition was allowed for a total discount of 44 percent).