When the taxpayer values a charitable contribution deduction of a remainder interest in a limited liability company at $33 million and the IRS values the same interest at about $4 million, there is the making of a controversy, especially when there is disagreement about the appropriate method for evaluation. The Tax Court has recently had to grapple with determining the proper method for evaluating the interest. Stephen Ross pledged a gift of $4 million (later increased to $5 million) to the University of Michigan for its Athletics Department. He agreed to transfer “or to have transferred” a remainder interest in a limited liability company that owned real estate leased to AT&T. The LLC...