Although it has been well established for years that discounts could be claimed on corporate stock (and some other ownership interests) for minority interest and nonmarketability, the courts until this year have resisted efforts to obtain a deduction for potential capital gains tax liability. However, two 1998 cases have been responsible for a break-through and have allowed discounts for potential income tax liability from liquidation in valuing corporate stock. Both Eisenberg v. Commissioner, and Estate of Davis v. Commissioner, involved stock valuation for federal gift tax purposes.