On January 28, 2021, the Indiana Supreme Court decided
Hartman v. BigInch Fabricators & Construction Holding Co., rejecting the short-lived distinction between divorce case business valuation discounts from discounts in other settings and establishing a new precedent for business law practitioners.
Revisiting the Case
BigInch was a closely held corporation in the business of fabricating and installing natural gas and pipeline stations and related apparatus. Blake B. Hartman was one of the founders and a former president of BigInch.
In 2006, the shareholders to the corporate predecessor of BigInch, each owning a minority position, entered into a shareholder agreement. The shareholder agreement required the company to purchase the shares of any shareholder who was involuntarily terminated as an officer or director of the company based on an appraised market value by a third-party valuation company. In 2018, Hartman was involuntarily terminated from his position as a director and o