Services
Large estate planning portfolios, property-rich operating companies, holding companies, fractional interests, and the control and marketability questions that follow.
What this covers
Qualified appraisal work for estate, gift, and generation-skipping transfer matters where the underlying interest is not a vanilla operating company. The recurring features include large estate planning portfolios, property-rich operating businesses, holding-company structures with operating and real-estate tiers, fractional interests, partnership and LLC interests, S-corporation valuations, and discounts at multiple tiers.
The work is built to survive IRS examination. That means a defensible enterprise-value build, transparent discount methodology, comparable transaction support that does not pretend the data set is bigger than it is, and a clean audit trail.
Who this is for
Built for the review audiences who actually scrutinize this work.
When to call LHM
Why this gets complicated
Discounts are where IRS examiners spend their time, and where careless work fails. Tier-by-tier construction matters: DLOC and DLOM applied at the wrong tier overstate the discount; ignoring asset-mix differences in studies overstates DLOM; failing to test against actual restricted-stock or pre-IPO data sets exposes the conclusion. Holdco-discount work has its own literature and its own pitfalls.
Tax-affecting S-corporation earnings, S-Corp premium analysis, and fractional-interest discounting are all areas where the case law and the academic literature have shifted. LHM follows the current state of both, and documents it.
What LHM evaluates
Standards and review audiences
Deliverables
Related reading
Mar 2026 · 10 min read
OBBBA raised the federal estate-tax exemption to $15 million per person. It didn’t repeal the rules that decide whether a discount survives review. Two recent cases, one from the Supreme Court and one from the Tax Court, show why the work matters more, not less.
Sep 2026
The number serves three purposes: estate-tax filing, basis step-up, and estate administration. Each pulls in a slightly different direction, and the IRS examination program reviews these filings closely.
Sep 2026
Taxpayers often use the word appraisal loosely, and the IRS does not. The qualified-appraisal rules govern who can sign, what content is required, and what timing applies, and a technically defective appraisal can disqualify the deduction even when the underlying value is correct.
Most engagements begin with a 20–30 minute conversation about scope, timing, and the right analytical path. There is no charge for an initial conversation.