- 15 - Additional Transfers to the Kerr Children On December 31, 1994, petitioners each transferred a .085- percent class B limited partnership interest in KILP to each of the Kerr children. On December 31, 1995, petitioners each transferred a .09375-percent class B limited partnership interest in KILP to each of the Kerr children. Petitioners' Federal Gift Tax Returns Petitioners filed Federal gifts tax returns for 1994 in which they reported gift tax liabilities attributable to the transfers that they made to the GRAT’s trustees and to their children. In an appraisal report (attached to the returns) prepared by Howard Frazier Barker Elliott, Inc., petitioners determined the fair market value of the KFLP class B limited partnership interests that they transferred to the GRAT’s trustees by applying a 25-percent discount for lack of liquidity or marketability to the value of the KILP interests held by KFLP, and a 17.5-percent minority-interest discount and a 35-percent discount for lack of liquidity or marketability on the net asset value of KFLP's assets. Petitioners computed the fair market value of a 44.535-percent limited partnership interest in KFLP as follows: Total net asset value (KFLP) $3,196,366 Less class A capital account 10,000 3,186,366 Limited partnership percentage 44.535% NAV of the interest 1,419,048 Minority-interest discount 17.5% 248,333 Marketable minority interest value 1,170,715 Discount for lack of marketability 35.0% 409,750 Fair market value 760,965Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011