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Revenue Ruling 93-12
Internal Revenue Service
1993-1 C.B. 202 (1993)
- Written by Eric Miller, JD
Facts
P owned all of a particular class of stock in X Corporation. P transferred the entirety of this stock to P’s five children—A, B, C, D, and E—each of whom received 20 percent interests in the X stock. The Internal Revenue Service considered the issue of whether the creation of minority interests in the stock gave rise to minority discounts—that is, discounts in the value of the stock based on the downside risks inherent in holding a minority interest.
Rule of Law
Issue
Holding and Reasoning ()
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