According to TAM 94360005, how does the IRS view discounts related to family businesses?

The IRS views discounts related to family businesses as facing ongoing scrutiny because these discounts often have significant implications for tax calculations and business valuations. The concern arises from the potential for these discounts to be manipulated or used strategically to reduce tax liabilities. As such, the IRS closely examines the rationale presented for such discounts to ensure they are justified and reflect true market conditions.

Discounts, such as those for lack of control or lack of marketability, are commonly applied in valuing family-owned businesses, but they must be well-supported by appropriate valuation methodologies and not simply assumed or claimed without rigorous justification. This scrutiny ensures compliance with tax regulations and addresses concerns about equity in taxation, particularly when family members may be engaged in estate planning or transfer of ownership.

In contrast, the other options suggest a more simplistic view of the IRS's stance, which does not align with the complexity and regulatory scrutiny that discounts, especially on family businesses, typically involve.