Estate of Gallagher v. Comr., T.C. Memo. 2011-148

(valuation of decedent's 15 percent interest in LLC at issue; estate valued interest at $34,936,000 and, on audit, IRS valued interest at $49,500,000; court determined that proper value wasless than what estate valued interest at - $32,601,640; estate entitled to refund of $861,422).