On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner from a GRAT and an irrevocable trust, respectively. Background to Grieve v. Commissioner – A Three Hour Tour This is the cautionary tale of Pierson Grieve, who I imagine has the look and affectations of Thurston Howell, III, sans the deserted island or the comic relief of Gilligan and the Skipper. Nor did Mr. Grieve have the Professor to engineer a way out of his tax liabilities with little more than coconuts and a sincere suspension of disbelief. He did have a cravat, though; that much I am sure of. Mr. Grieve had a daughter, Margaret, a lawyer,…