Business Valuation for Gift Tax

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Business valuations for gift tax filings, supporting accurate Form 709 reporting of closely held interests. AppraiseItNow delivers certified fair market value opinions with full Revenue Ruling 59-60 analysis.

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DEFENSIBLE, USPAP-COMPLIANT BUSINESS APPRAISAL REPORTS — QUALIFIED FOR THE IRS, PROBATE COURTS, AND ESTATE ATTORNEYS.

  • IRS
  • United States Courts
  • Chase
  • Bank of America
  • State Farm
  • Goodwill Industries
  • Wells Fargo

The business valuation team behind your fair market value appraisal

Between them, our business valuation appraisers hold ASA, ABV, and CFA designations, and every report is written to USPAP for the IRS, probate courts, and estate attorneys.

Joe Kattan

Joe Kattan

Owner & CEO

Joe founded AppraiseItNow to make a certified, USPAP-compliant appraisal as simple to order as anything else online. A former Bain & Company strategy consultant, Joe leads the entire team and specializes in strategy, growth, and the firm's tech capabilities.

Justin Ramirez

Justin Ramirez

Business Valuation Expert & Appraiser

ASA, ABV, and CFA charterholder. Since 2016 Justin has valued businesses for estate and gift tax, purchase price allocations, fairness opinions, lending, and buy-sell agreements, across manufacturing, services, retail, and pre-revenue biotech.

Raymond Ghelardi

Raymond Ghelardi

Business Valuation Expert & Appraiser

Accredited Senior Appraiser with the American Society of Appraisers. Raymond values capital stock, business enterprises, stock options, and intangible assets.

Aron Blue

Aron Blue

Client Success Manager

Manages each engagement from the first enquiry to the delivered report, and keeps you posted at every step along the way.

  • USPAPWritten to the Uniform Standards of Professional Appraisal Practice
  • Fair market valueThe IRS definition of value that Form 706, probate courts, and gift tax filings apply
  • American Society of AppraisersAccredited Senior Appraiser
  • AICPAAccredited in Business Valuation
  • CFA InstituteChartered Financial Analyst
  • The Appraisal FoundationAuthorized by Congress as the source of appraisal standards

Business Appraisals for Gift Tax Purposes

Transferring an ownership interest in a privately held company triggers a federal reporting obligation whenever the value exceeds the 2025 annual exclusion of $19,000 per recipient, and a qualified appraisal is required to substantiate the fair market value reported on Form 709. Because closely held business interests have no quoted market price, the IRS relies on Revenue Ruling 59-60 and related guidance to evaluate whether the reported value reflects what a willing buyer and seller would agree upon at the exact date of the gift. Our business valuation practice produces reports that address every factor the IRS expects to see, from earnings history and dividend-paying capacity to applicable discounts for lack of control and lack of marketability.

AppraiseItNow delivers these valuations both online and onsite across the United States, working with business owners, estate planning attorneys, CPAs, and family offices navigating complex transfers. Whether you need support for a single minority interest gift or a multi-year gifting program, our gift tax valuation services are structured to satisfy adequate disclosure requirements and start the three-year statute of limitations.

Business Interests We Appraise for Gift Tax

AppraiseItNow covers the full range of privately held business structures and interest types commonly transferred as gifts.

  • Minority interests in family limited partnerships (FLPs) and family limited liability companies (FLLCs)
  • Majority and controlling interests in closely held C corporations and S corporations
  • Non-voting stock in family-owned operating companies
  • Membership interests in multi-member LLCs with operating agreements restricting transfer
  • General and limited partnership interests in holding entities
  • Interests in professional practices including medical, dental, legal, and accounting firms
  • Ownership stakes in family-owned manufacturing, distribution, and service businesses
  • Interests in holding companies with mixed asset portfolios including securities and operating subsidiaries
  • Fractional interests in business entities where buy-sell agreements or transfer restrictions affect marketability

How AppraiseItNow Approaches Business Gift Tax Valuations

Our appraisers hold credentials from recognized professional organizations including ASA, ISA, and AMEA, and are experienced in applying Revenue Ruling 59-60 and IRS gift tax regulations to closely held business interests.

  • Each engagement begins with a review of the entity's financial statements, operating history, and ownership structure, typically covering five years of balance sheets and income data as required for adequate disclosure on Form 709.
  • Appraisers select and document the appropriate valuation approaches, including the income approach, market approach using guideline public companies or transactions, and asset-based methods, with full explanation of how discounts for lack of control and lack of marketability were determined.
  • The completed report is dated as of the exact gift date, prepared specifically for gift tax purposes, and structured to meet IRS qualified appraisal standards, including all assumptions, methodologies, and supporting documentation needed to withstand audit scrutiny.
  • Delivery is available on an expedited basis when Form 709 deadlines are approaching, and our team coordinates directly with attorneys and CPAs to ensure the report integrates cleanly with the overall filing.

Discount Analyses That Lower the Reportable Value of a Gifted Interest

A minority interest transferred to family is worth less than its share of the whole company, and the discount analysis is the most frequently contested part of a gift tax valuation. We document both discounts so the value reported on Form 709 stands.

Independent by rule

Unbiased does not mean undiscounted.

We do not start from the number you would like to report. We start from the interest itself: its rights, its restrictions, its liquidity. The discount is whatever that evidence supports, and the report walks an IRS reviewer through every step. Three things keep the conclusion independent:

  • Prepared in accordance with USPAP, which bars an appraiser from taking a fee that depends on the value reported.
  • Fair market value as the Treasury defines it: a willing buyer and a willing seller, neither under any compulsion, both informed.
  • Argued under Revenue Ruling 59-60, the same framework the IRS trains its own valuation analysts on.
How a discount is builtIllustrative. No figure here is a quote.
  1. Pro rata share
  2. Less: lack of control
  3. Less: lack of marketability
  4. Fair market value

DLOC

Discount for Lack of Control

A minority holder cannot set distributions, compensation, or the timing of a sale, so a buyer pays less for the interest than for a controlling stake.

What we examine to size it:

  • Voting, veto and consent rights the interest carries
  • Who decides distributions, salaries and reinvestment
  • Whether the holder can force a sale, dissolution or redemption

DLOM

Discount for Lack of Marketability

Closely held shares have no ready market, and the time and cost of finding a buyer make the interest worth less than freely traded stock.

What we examine to size it:

  • Transfer restrictions and rights of first refusal in the governing documents
  • Distribution history and the expected holding period
  • The pool of realistic buyers and any path to liquidity

The Support Behind Every Discount We Apply

These discounts are not an appraiser’s courtesy. Decades of IRS guidance, Tax Court decisions and market evidence define them, and the same sources are what an examiner reads:

  1. 1959IRS guidance

    Revenue Ruling 59-60

    The IRS framework for valuing closely held stock: eight factors, among them the size of the block being valued and the market for it.

  2. 1971Market evidence

    SEC Institutional Investor Study

    The first large study of what buyers paid for restricted shares, and the start of decades of restricted stock and pre-IPO studies. The IRS recognized their relevance in Revenue Ruling 77-287.

  3. 1982Tax Court

    Estate of Andrews, 79 T.C. 938

    A family member’s shares are valued as what they are, not as part of the family’s combined control, and lack of marketability is a discount in its own right.

  4. 1993IRS guidance

    Revenue Ruling 93-12

    The IRS accepted minority discounts on transfers to family members even where the family as a whole controls the company, reversing its earlier position in Revenue Ruling 81-253.

  5. 1995Tax Court

    Mandelbaum v. Commissioner

    Judge Laro’s list of factors for sizing a marketability discount, still the checklist courts, the IRS and appraisers work from.

  6. 2009IRS guidance

    IRS DLOM Job Aid

    The guide the IRS wrote for its own valuation analysts, cataloguing the restricted stock studies, pre-IPO studies and analytical models that support a discount for lack of marketability.

Every discount we apply is supported with empirical evidence, including restricted stock studies and market transaction data, and documented under the Revenue Ruling 59-60 framework. The facts of each interest determine the discount; we never apply a preset percentage.

What clients say we are known for

AppraiseItNow Reviews: “The report was quite thorough as well” and “The team was highly knowledgeable, helpful, and efficient”

  1. Being the appraiser they come back to“I highly recommend their appraisal services, especially for private companies” Steve R.Mentioned in 44 reviews
  2. Answering fast, and staying reachable while the work runsMentioned in 34 reviews
  3. Showing the research and the comparables behind the number“Their work was quick, thorough” Jeff H.Mentioned in 29 reviews
  4. Delivering the finished report ahead of the deadlineMentioned in 21 reviews
  5. Taking on items other appraisers had already turned downMentioned in 14 reviews

Across 80+ published AppraiseItNow reviews the picture is consistent: every one is from a client who paid us for an appraisal, and the three things they raise most often are that they would hire us again, how quickly we answer, and how much research is visible in the report.

  • Responsive, professional, first class deliverables -- especially considering that that the appraised assets are extremely complex financial assets with little by way of comps. The deliverable satisfied my accountants and advisers as being more than adequate to support the valuation needed to complete a conversion to a Roth IRA
    Dave T., Ocala, FL ·

    Business Valuation Appraisal for IRA Conversion

  • Joe and Aron were extremely impressive - the entire process went very smoothly. They were always quick to respond to any questions I had and could not have been more helpful. They were aware of some tight time restrictions I had and made sure I received my reports in a timely fashion. I highly recommend them to anyone needing a valuation.
    William L., Woodford County, IL ·

    Business Valuation Appraisal for Charitable Donation

  • I used AppraiseItNow to examine a contribution to a foundation. Their work was quick, thorough, and easy to work with, as they’ve developed a simple system for uploading documents. I plan to use them again.
    Jeff H. , New York, NY ·

    Business Valuation Appraisal for Charitable Donation

  • The team was highly knowledgeable, helpful, and efficient. I highly recommend their appraisal services, especially for private companies.
    Steve R., Northbrook, IL ·

    Business Valuation Appraisal for IRA Conversion

  • I found them professional & responsive. The report was quite thorough as well.
    Daniel L. , New York City, NY ·

    Business Valuation Appraisal for Charitable Donation

  • From the start they were very responsive, price competitive, and had a quick turn around time. Thank you so much to Joe who was very sweet in responding to my emails; I am looking forward to utilizing AppraiseItNow for many years to come.
    Chris S., San Clemente, CA ·
  • Very thorough and professional — great communication and outstanding service. Highly impressed with their work!
    Curt B. , Washington, UT ·

Frequently Asked Questions on Business Valuation for Gift Taxs

How is a gifted business interest valued for gift tax?

At fair market value on the date of the gift, as required by IRC Section 2512: the price a hypothetical willing buyer would pay a willing seller, both reasonably informed and neither compelled. That date-specific value is the amount reported on Form 709, and later company performance generally cannot reset it.

Does the price a family member pays set the taxable value?

No. The hypothetical buyer is not presumed to be the donor's child, so below-market family pricing does not reduce the reportable gift. The difference between fair market value and what the donee actually pays is itself treated as the taxable gift, which is why the IRS routinely challenges values based on intra-family transaction prices.

When does a gifted interest need a formal valuation report?

Whenever the transfer to one recipient exceeds the annual exclusion ($19,000 per recipient for 2025), practitioners expect a documented qualified appraisal supporting the Form 709 value, since closely held interests have no quoted market price. A bare number without a compliant report covering methods, assumptions, and the valuation date is a common audit vulnerability.

How does the IRS review gift tax business valuations?

IRS engineers apply the Business Valuation Guidelines in Internal Revenue Manual 4.48.4, checking whether the report addresses the eight Revenue Ruling 59-60 factors, justifies its choice among market, income, and net asset approaches, and supports any discounts for lack of control or marketability with empirical evidence. Minority-interest discounts are the most frequently contested item.