Among the newer MID processes that have emerged to fill in the gaps in cost, flexibility, and part complexity, one that is attracting the most attention is the laser direct structuring (LDS) process from LPKF.
Unlike other MID processes, LDS is very flexible because circuit designs can be modified simply by reprogramming the laser unit.
Heininger views LDS as a breakthrough technology that will bring more users into the MID fold.
Ticona worked with MID maker Harting Mitronics in Biel, Switzerland, to develop the first commercial LDS application made of LCP.
Under very complicated facts, the Service collapsed the transfers and treated the decedent as having transferred her entire interest to her son simultaneously, thereby disallowing any claimed MID.
This was seen as a capitulation by the Service on the MID issue.
However, that appraiser applied only a 25% MID and LOMD, because he believed that the decedent's 10% of the Class A voting stock had some swing vote characteristics and could create majority control in the hands of the Simmons family, and that the sale of the decedent's shares might cause the two families to compete for the stock, thereby increasing its sales price.
The court ruled that the voting stock was worth 10% more than the nonvoting stock (before discounts) and that no MID would be allowed because of the swing vote attributes.
When this intent was lacking, as in Chandler,(17) the transferred stock was not assigned a premium; when this intent was manifest, as in Brush,(18) a MID was disallowed.
The refund claim reported the value using the capitalization-of-earnings method and a 30% MID. The court ruled that because there was a market for the minority interest among the company or persons associated with it, there was no need for a MID.