Key legal question
Whether the spouses were entitled to the 30% minority-share discount for unlisted participations in wealth tax valuation.
Extracted holding
No. The discount may be refused where spouses together effectively control the companies and the minority status is only apparent.
Extracted reasoning
The SSK valuation guide is not binding federal law but a guideline that may be deviated from when the concrete control situation makes the pauschal discount unjustified. Here the spouses jointly controlled the companies, so the participations had to be valued cumulatively without the minority discount.