Valuation of Blocks of Stock: A Number of Unresolved Issues Still Remain .

Abstract Administration of the transfer taxes requires that all property transferred must be valued. When the property transferred is a block of corporate stock, that valuation task presents a myriad of problems. After decades of IRS pronouncements and judicial decisions dealing with this valuation task, many questions remain unanswered. This article discusses two of the many unresolved issues. First, the author presents the general framework for deciding if a minority discount, blockage discount, or control premium is applicable. Then, the article explores the question of precisely what stock is relevant to the valuation task and the role that family control of the corporation plays in the valuation process.