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A created a trust through a gift to the grantor trust for the benefit of family members. The business interest they transferred consisted of a
A created a trust through a gift to the grantor trust for the benefit of family members. The business interest they transferred consisted of a gift of a 1% general partner interest and a subsequent gift of a 65% limited partner interest. In valuing the gift of 65% of the limited partnership interest: a. The 1% general partner interest will be considered in the value, because this is an intra-family transaction b. The minority interest discount will not be available because the sum of the gifted interest plus the retained limited partner interest exceeds 50% of the partnership c. The lack of control discount will not be available because the grantor retains the 1% general partnership interest d. Each interest will be evaluated separately; thus, both the minority interest discount and the lack of control discount could be available
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