Estate of Fred O. Godley, Deceased Fred D. Godley, Administrator Cta v. Commissioner of Internal Revenue

Affirmed by published opinion. Chief Judge WILKINSON wrote the opinion, in which Judge NIEMEYER and Judge MICHAEL joined.

OPINION

WILKINSON, Chief Judge.

The Estate of Fred 0. Godley (“Estate”) appeals the decision of the Tax Court valuing Godley’s fifty percent interest in five general partnerships and determining an estate tax deficiency of $247,714. The Estate contends that the Tax Court should have applied a minority discount by discounting Godley’s interest in the partnerships because he lacked control over them.

Whether a minority discount is appropriate in a given situation is part of the…