Murphy v. U.S. (filed 10/2/09)

In this U.S. District Court case, the Court held that section 2036(a) did not cause assets transferred to an FLP and a LLC to be included in the estate of the decedent. A minority discount of 12.5% and a marketability discount of 32.5% was applied to the 95.25365% FLP limited partnership interest, and a combined lack of control/marketability discount of 20% was applied to the general partnership interest. A minority discount of 11.1% and a marketability discount of 32.5% was applied to the 49% member interest in the LLC.


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