Pierce v. Commissioner, T.C. Memo 2025-29, April 7, 2025
The court reviewed a discounted cash flow valuation of a privately held S Corporation after gifts and sales of interests. It found the taxpayer’s expert assumptions credible, including cash flow projections, long-term growth, and analysis of nonoperating assets. The court accepted reasonable discounts for lack of control and lack of marketability, emphasizing that all assumptions and adjustments must be well-supported and thoroughly documented.