Over the last 30 years, substantial changes have emerged over the taxation of co-owned assets (other than joint tenancy) at death.1 Interests in real property held as community property have been eligible for a discount in value for unmarketability of the decedent’s fractional interest, at least since 1982.2 However, discounts for undivided interests in tenancy in common ownership of property otherwise were rejected until fairly recently.3



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