Closely-held interest transferred at NAV with no discount applied.
A 2023 gift of a 22% interest in a family LLC was documented at net asset value. No discount for lack of marketability or lack of control was taken. Appraisal on file supports a combined discount range of 28%–34%.
2023 gift tax return · Form 709 line 3 — reported value $2,640,000. Appraisal dated Jan 2023 supports DLOM 14% + DLOC 18%. Client used $2.64M of lifetime exemption.
Whether an amended 709 is viable inside the statute of limitations. Whether the appraiser's scope covered the minority interest specifically or only the full entity.
Evaluate an amended 709 applying a combined discount — projected exemption restored: $740K–$900K.
Modeled on the 28%–34% discount band in the existing appraisal. Labeled Projected. Would require engagement with the CPA of record and an updated appraisal letter.