Federal Estate Tax Discounts for Potential Income Tax Liability for Retirement Accounts?

Abstract

<p>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.<strong>1 </strong>And it has been clear for nearly two decades that discounts could be claimed for co-ownership interests as well.<strong>2 </strong>Moreover, for nearly a decade, in valuing corporate stock, courts have allowed a discount for potential income tax liability.<strong>3</strong></p>