Legal Opinion
Adams v. United States
Court of Appeals for the Fifth Circuit
Decided July 5, 2000No. 99-10497PublishedCited by 26 opinions
1Opinion of the Court
WIENER, Circuit Judge:
This estate tax ease presents a single issue: Whether discounts for lack of control, lack of marketability, and poor portfolio diversity are applicable when appraising the value of an assignee’s fractional interest in a Texas general partnership for estate tax purposes. The district court correctly identified the relevant interest of the partnership in question — that of a partner’s assignee, not that of a full-fledged partner — but reached the erroneous legal conclusion that the assignee of a 25 percent partner’s interest has a “well-established” right to receive a 25…
2Cases cited19 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- United States v. CartwrightSupreme Court of the United States · 1973
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Fuji Photo Film Company, Inc., Cross-Appellee v. Shinohara Shoji Kabushiki Kaisha and Graphic MacHinery International, Inc., Cross-AppellantsCourt of Appeals for the Fifth Circuit · 1985
14 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Whitehouse Hotel Ltd. Partnership v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
- John David Smith, of the Estate of Louis R. Smith, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 2004
- Anastos v. SableMassachusetts Supreme Judicial Court · 2004
- PBBM-Rose Hill, Ltd. v. Comm'r of Internal RevenueCourt of Appeals for the Fifth Circuit · 2018
- Estate of True v. CommissionerCourt of Appeals for the Tenth Circuit · 2004
21 more not listed; retrieve them via the Exa API.