Purposes of Inclusion in the Augmented Estate?
Lawrence appeals the district court’s valuation of the 96% interest in HFLP conveyed to him in March 2000 by his father. He argues that the district court employed “fair value” rather than “fair market value” and, accordingly, failed to consider or apply discounts for lack of marketability and lack of control that were inherent in his limited partnership interest. Maryam maintains that there is no evidence to demonstrate the district court employed any valuation other than fair market value and that the court’s refusal to consider such discounts was appropriate based on the absence of her consent to Norman’s transfer of the interest to Lawrence. Details of the transaction are essential to our analysis. The March 2000 transaction was achieved partially by gift and partially by sale. The gift portion consisted of a transfer of that extent of the HFLP limited partnership interest having a fair market value of $675,000; this was the maximum transfer without incurring gift tax under the Int
