Is a 25% interest in a company worth 25% of the company's value?
Rarely. Fractional interests are not appraised as a simple pro-rata slice because minority holders lack control and face illiquidity, so appraisers apply documented discounts for lack of control and lack of marketability after valuing the underlying entity. The interest's actual rights and transfer restrictions, not just the percentage, drive the discounts.
What does Revenue Ruling 59-60 require when valuing a closely held interest?
A multifactor analysis with no fixed formula. The ruling directs appraisers to weigh the nature and history of the business, economic and industry outlook, earning capacity, dividends, goodwill, block size, and prices of comparable traded stocks. The IRS recognizes no safe-harbor discount percentage, so each New Jersey fractional interest must be supported case by case.
How does New Jersey tax a fractional business interest at death?
Through the transfer inheritance tax, valued at clear market value on the date of death; the separate state estate tax ended for deaths after January 1, 2018. Appraisals of intangible personal property for the tax are handled by auditors at the Transfer Inheritance Tax Branch, which makes a well-documented valuation of the interest important support for the filing.
Must every valuation approach be addressed for a partial interest?
Yes. ASA Business Valuation Standards direct appraisers valuing partial interests to consider the asset-based, income, and market approaches and to explain in the report why any approach was excluded. Unexplained omissions are a recurring weakness in contested valuations, and courts and IRS reviewers look for them.