Estate of Jelke v. Comm'r
United States Tax Court
D's gross estate included a 6.44-percent interest in a closely held corporation (C) whose assets consisted primarily of marketable securities. C had been in existence for many years, was well managed, and had a relatively high rate of return in the form of annual dividends coupled with capital appreciation of approximately 23 percent annually for the 5-year period before D's death.
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D's gross estate included a 6.44-percent interest in a closely held corporation (C) whose assets consisted primarily of marketable securities. C had been in existence for many years, was well managed, and had a relatively high rate of return in the form of annual dividends coupled with capital appreciation of approximately 23 percent annually for the 5-year period before D's death. Also during this 5-year period, there was no intent to completely liquidate C, and its securities turnover (sales) averaged approximately 6 percent annually. At the time of D's death, the securities had a market…
1Opinion of the Court
ESTATE OF FRAZIER JELKE III, DECEASED, WACHOVIA BANK, N.A., f.k.a. FIRST UNION NATIONAL BANK, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Jelke v. Comm'r
No. 3512-03
United States Tax Court
T.C. Memo 2005-131; 2005 Tax Ct. Memo LEXIS 128; 89 T.C.M. (CCH) 1397;
May 31, 2005., Filed
D's gross estate included a 6.44-percent interest in a closely
held corporation (C) whose assets consisted primarily of
marketable securities. C had been in existence for many years,
was well managed, and had a relatively high rate of return in
the form of annual dividends…
2Cases cited18 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
13 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Estate of Jelke v. CommissionerCourt of Appeals for the Eleventh Circuit · 2007
- Estate of Elkins v. Comm'rUnited States Tax Court · 2013
- Steinberg v. CommissionerUnited States Tax Court · 2013
- Estate of Elkins v. Comm'rUnited States Tax Court · 2013
- Estate of James A. Elkins, Jr., Margaret Elise Joseph and Leslie Keith Sasser, Independent Executors v. CommissionerUnited States Tax Court · 2013
7 more not listed; retrieve them via the Exa API.