Category Archives: Discounts

In Re Marriage of Schorer v. Schorer

Accepting Bonfield’s valuation of canning business not clearly erroneous. Bonfield used a 20% premium because of husband’s controlling interest and a 20% discount for reduced marketability.

Year: 1993 | State: WI

In Re Marriage of Popp v. Popp

Husband’s testimony alone insufficient to warrant discount factor for nonmarketability and minority position. Expert opinion needed.

Year: 1988 | State: WI

Drumheller v. Drumheller

Appellate court affirmed trial court’s valuation which rejected proposed minority discount.

Year: 2009 | State: VT

Owens v. Owens

No minority discount where husband owned 50 percent interest in a family-owned business and his brother owned the other 50 percent.

Year: 2003 | State: VA

Kress v. United States

Discounts for lack of marketability found to be 27% and 25%. No premium or discount for S corporation.

Year: 2019 | State: US

Richarz v. Richarz

(1) A minority discount did not apply in valuing marital property consisting of husband’s interest in an LLC in which he was minority owner, where the LLC was a family LLC (2) A lack-of marketability discount did not apply either, since the primary value of the LLC was in real estate and it was unlikely a sale would ever occur.

Year: 2017 | State: SD

Adams v. Adams

Discounts for lack of marketability and lack of control affirmed.

Year: 2015 | State: SD

Clark v. Clark

Family court could determine that marketability discount was applicable to wife’s 25% interest in closely held family business. A lack of control discount was also reasonable.

Year: 2020 | State: SC

Matter of Marriage of Brancomb

No minority or marketability discount where partnership agreement means that minority shares would never have to be sold on the open market.

Year: 2005 | State: OR

Matter of Marriage of Barlow

Discount of 25% for 15% ownership of a family business affirmed. Higher discount rejected, as no minority sale was planned.

Year: 1992 | State: OR

In Re Marriage of Williams

Trial court reversed for discounting corporation for lack of control where son and father each owned one-half.

Year: 2009 | State: MT

Marriage of Danelson

Applying 40% discount to business in which each party had a 50% interest is reversed as husband had full control over corporate affairs.

Year: 1992 | State: MT

Cox v. Cox

50 percent discount for lack of marketability affirmed.

Year: 2011 | State: MS

Bernier v. Bernier

Trial court erred in using C-Corp tax rates for an S-Corporation. Also, the trial court erred in using “key man” and marketability discounts where the businesses (supermarkets) were not going to be sold.

Year: 2007 | State: MA

In Re Marriage of Conner

Trial judge could not take judicial notice of discount of lack of marketability.

Year: 1999 | State: IN

Miller v. Miller

Court affirmed for not applying marketability discount where company was highly marketable due to high return.

Year: 1995 | State: FL

Brooks v. Brooks

Trial court erred by valuing interest in LLCs without examining lack of marketability and lack of control.

Year: 2010 | State: CT

Siracusa v. Siracusa

No minority discount should be applied where the parties were sole shareholders and husband awarded 100% of the shares.

Year: 1993 | State: CT