Estate of Beatrice Weinstein v. United States

DAVID A. NELSON, Circuit Judge.

This is a federal estate tax case that turns on whether a decedent’s interest in a certain trust established by the decedent’s late husband was capable of valuation under “recognized valuation principles,” a term used in the pertinent Internal Revenue Service regulations. If the widow’s interest could be so valued, her estate was entitled to an estate tax credit in the amount of a portion of the taxes paid on the husband’s estate, the husband having predeceased his wife by six months. (See 26 U.S.C. § 2013, which provides for such a tax credit, under certain…