Case Conclusion Date:June 17, 2011
Outcome:Full amount of mortgage was allowed as discount on audit of estate tax return.
Description:Real property was fractionalized between revocable and irrevocable trusts. Minority and marketability discount was taken in valuation for estate tax purposes. Recourse mortgages were deducted at full value and not discounted for minority and marketability, ie they were not netted against property values before discounting.