What standard of value applies to a business interest reported on Form 706?
Federal estate tax requires fair market value as defined in Treasury Regulation 20.2031-1: the price a hypothetical willing buyer would pay a willing seller, neither under compulsion and both reasonably informed, measured at the date of death. Alternative standards such as investment value or intrinsic value are not accepted for estate tax reporting, and neither is a price negotiated within the family.
How does Revenue Ruling 59-60 shape an estate tax business valuation?
It requires the appraiser to analyze the company's history, financial condition, earning capacity, dividend-paying capacity, goodwill, prior sales of the stock, the size of the block being valued, and comparable companies rather than applying a single formula. The IRS expects the report to identify the exact ownership interest, the valuation date, and the income, market, or asset approaches used, supported by financial data.
Why do valuation discounts draw IRS scrutiny on estate returns?
Because discounts for lack of control and lack of marketability can reduce the reported value substantially, the IRS examines whether they are justified by evidence about the specific interest's size, rights, transfer restrictions, and liquidity. Estate tax disputes over closely held businesses frequently center on discount magnitude, so we document the support for every discount applied rather than citing generic percentages.
Can an estate simply use the company's book value?
No. Estate tax is based on fair market value, not original cost or balance-sheet equity, and IRS examiners cite Revenue Ruling 59-60 to reject valuations that rely on book value alone. Earning power, cash flows, goodwill, and market comparables must enter the analysis, and marketable securities must be valued from market quotations around the valuation date.