Scenario: Alan establishes a Family Limited Partnership $($FLP$),$ transferring $$12,000,000$ in real estate for a $1\%$ general partnership interest, while his children receive $1\%$ each as limited partners. Alan gifts $30\%$ limited partnership interest to each child.

What is the potential discount Alan can apply to the gifted partnership interests for gift tax purposes?

A control premium

Marketability discount

Both lack of marketability discount and lack of control discounts

No discount can be applied