Services

Estate and Gift Valuation

Business, real estate, and ownership-interest valuations for estate and gift filings of any size: a single commercial property, a closely held company, a large planning portfolio, or fractional interests, with the control and marketability questions that follow.

Need a real-estate-only estate or date-of-death appraisal? See Date-of-Death and Estate Appraisal.

What this covers

The work in plain English.

Valuation support for estate, gift, and generation-skipping transfer matters, from a conventional operating company or a single commercial property to 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. Each filing has its own support rules: Form 706 asks for the appraisals and financial data behind reported values, Form 709 adequate disclosure calls for a qualified appraisal as its regulation defines it or a detailed description of the method, and charitable gifts follow the separate qualified-appraisal rules of IRC §170.

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.

  • Estate counsel
  • Tax attorneys
  • CPAs
  • Trustees
  • Family offices

When to call LHM

Specific situations where this engagement is the right fit.

  • A conventional business or a single property needs a supportable value for a Form 706 or Form 709 filing
  • A large estate planning portfolio needs consistent valuations across real estate, entities, and fractional interests
  • An estate includes a closely-held operating business with significant real estate
  • A holding company structure raises tiered-discount questions (DLOM, DLOC, holdco discount)
  • A fractional or tenancy-in-common interest needs a defensible discount
  • A gift needs adequate disclosure on Form 709, or a charitable gift needs a qualified appraisal under §170
  • Estate counsel needs an appraiser whose work has held up under IRS examination

Why this gets complicated

The technical nuances that decide the answer.

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

Analytical components.

  • Enterprise value (income, market, asset approaches)
  • Real-property fair market value (separately when property is a meaningful component)
  • Tier-by-tier discount analysis (DLOC, DLOM, fractional-interest, holdco discount)
  • Tax-affecting analysis for pass-through entities
  • Marketability studies and restricted-stock benchmarking
  • Reconciliation of valuation tiers to a defensible final conclusion

Standards and review audiences

The frameworks the work has to clear.

IRC §2031
Estate-tax fair market value standard, with §170 / §664 / §2512 corollaries.
IRC §2512 / Treas. Reg. §301.6501(c)-1(f)
Gift-tax value and the adequate-disclosure rules that start the statute of limitations on a Form 709.
USPAP
Uniform Standards of Professional Appraisal Practice, current edition.
IRS Rev. Rul. 59-60
Closely-held stock valuation factors, still controlling for fair-market-value gift and estate work.

Deliverables

What you receive.

  • Appraisal report matched to the filing: Form 706 support under §2031, Form 709 adequate disclosure under §2512 and Treas. Reg. §301.6501(c)-1(f), or a qualified appraisal under §170 for charitable gifts
  • Discount methodology memo with study citations
  • Comparable-company and comparable-transaction analyses
  • IRS-examination response capacity

Related reading

Field notes on this kind of work.

Estate & Gift Valuation

The threshold moved. The valuation problem didn’t.

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.

Discuss an estate or gift valuation

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.