Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas, N.A., Independent v. Commissioner of Internal Revenue

EDITH H. JONES, Circuit Judge:

The Estate of Helen Jameson appeals following a Tax Court decision assessing a deficiency against it. The Estate argues that the Tax Court clearly erred in valuing assets of Johnco, Inc. (“Johnco”), a holding company that is part of the estate. It also raises a plausible but unsustainable consti-. tutional challenge to the estate tax as applied in this case. As we agree that the court’s valuations were in error, we vacate and remand for further proceedings.

I. FACTS

This dispute arises from a series of bequests from John Jameson to his wife Helen Jameson, and from…