Legal Opinion
Estate of J. E. O'connell, James O'COnnell v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 20, 1981No. 79-7090PublishedCited by 36 opinions
1Opinion of the Court
SNEED, Circuit Judge:
This case involves a dispute over the valuation for estate tax purposes of two blocks of stock in close corporations held by the decedent, J. E. O’Connell, at his death. One block is an 80% interest in R. V. Ranch Corporation (R.V.); the other is a 95% interest in Capri Corporation (Capri). The applicable code section is 26 U.S.C. § 2031. The appellant seeks to overturn the valuations fixed by the Tax Court. This court’s jurisdiction lies under 26 U.S.C. § 7482 (1976). We affirm in part and reverse and remand in part.
I
THE FACTS
Capri was a holding company whose assets…
2Cases cited19 opinions
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Daniel D. And Agnes H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
14 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
- Gary L. Eyler v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
- Estate of Chenoweth v. CommissionerUnited States Tax Court · 1987
- Jameson v. CommissionerUnited States Tax Court · 1999
- Estate of Simplot v. Comm'rUnited States Tax Court · 1999
31 more not listed; retrieve them via the Exa API.