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general lack of marketability discount. Shares in a nonpublic
corporation suffer from lack of marketability because of the
absence of a private placement market and the fact that
floatation costs would have to be incurred if the corporation
were to offer its stock publicly. Estate of Andrews v.
Commissioner, 79 T.C. at 953. However, there are no such
barriers to the disposition of assets held within the IRAs. The
assets in the IRAs are traded on established markets and
exchanges, unlike stock in a closely held corporation. Although
the IRAs themselves are not marketable, the underlying securities
of the IRA are indeed marketable. Neither the distribution of
the assets in the IRAs nor the payment of the tax upon
distribution is a prerequisite to the marketability of the
assets, as the estate implies. Therefore, a lack of
marketability discount is not warranted. If we were to follow
the estate’s line of reasoning, then in any circumstance where a
seller recognizes gain on the disposition of an asset, the fair
market value of an asset would be reduced to reflect taxes
attributable to the gain. Further, as this Court observed in
Estate of Robinson v. Commissioner, 69 T.C. 222, 225 (1977), a
similar case discussed further infra, the broad ramifications of
such an argument--
demonstrate its frailty. For instance, under that
approach, every determination of fair market value for
estate tax purposes would require consideration of
possible income tax consequences as well as a myriad of
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