Estate Tax - Is the IRS a Weapon in Challenge of Valuation Discounts?

The IRS can easily say that what dad has really done here via series of steps is to make gifts to the assets transferred the entity and not the entity interest to his children. And therefore, valuation discounts for lack of control, lack of marketability with respect to the entity interest probably won't be available. The IRS position there has been emboldened in light of its success in the 2017 full tax court decision of a state of pal.