Valuation Discount on Lien Discharge Is Discretionary

In an email, the IRS advised that there is "nothing in the Code, the regulations, or the IRM that requires the Service to apply a minority interest discount in discharge cases."  The email clarified that judicial review is available under 7426(a)(4) for discharges issued under section 6325(b)(4) but discharge under any other provision is discretionary.

See "IRS Not Required to Apply Valuation Discount in Lien Discharge Cases," 2010 TNT 233-75 (July 9, 2010).

Posted by James G. Haskell, Senior Associate Editor, Wealth Strategies Journal.