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

(IRS asserted $7,000,000 deficiency in federal estate tax from decedent's estate due to valuation issues concerning 3,970 units of LLC interests included in estate; estate's expert valued interests at $28.2 million and IRS at $40.863 million with both appraisers using discounted cash flow approach; court's rejected estate appraiser's removal of non-recurring income items due to lack of explanation as to non-recurrence; court rejected IRS appraiser's use of guideline company analysis; estate's expert failed to explain reasons for taking discount for BIG tax in calculating future cash flows; court performed its own discounted cash flow analysis and arrived at value of $32,602,000).