Legal Opinion
United States v. Land
Court of Appeals for the Fifth Circuit
Decided May 16, 1962No. Nos. 18958 and 18959PublishedCited by 59 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
These cases pose a problem in the valuation, for federal estate tax purposes, of a partnership interest subject to a restrictive agreement limiting the sales price of the interest to two-thirds of its value in the event of its sale during the partner’s lifetime. The district court agreed with the taxpayers that the restriction limited the valuation to two-thirds of the property’s calculated net value. We reverse. A restriction on the value of a partnership interest that expires at the decedent’s death cannot affect the valuation of the interest for estate tax purposes.
The…
2Cases cited18 opinions
- Knowlton v. MooreSupreme Court of the United States · 1900
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Saltonstall v. SaltonstallSupreme Court of the United States · 1928
- Edwards v. SlocumSupreme Court of the United States · 1924
- Helvering v. SalvageSupreme Court of the United States · 1936
13 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Ahmanson Foundation v. United StatesCourt of Appeals for the Ninth Circuit · 1981
- Estate of Bernard Curry, Union Bank and Trust of New Albany, Trustee v. United StatesCourt of Appeals for the Seventh Circuit · 1983
- J. C. Shepherd v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 2002
54 more not listed; retrieve them via the Exa API.