Legal Opinion
Rushton v. Commissioner
Court of Appeals for the Fifth Circuit
Decided July 26, 1974No. 73-3438PublishedCited by 25 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
The Commissioner and the taxpayers come to this Court embroiled in a controversy over the interpretation and application of a concept in securities valuation commonly known as “blockage.” When any property is assessed for the purpose of imposing a federal tax— whether income, gift, or estate — the dollar amount assigned to it rests, at least theoretically, on the notion of fair market value. See Champion v. Commissioner of Internal Revenue, 5 Cir. 1962, 303 F.2d 887. The Treasury Regulations on the Gift Tax are typical in defining that ideal as “the price at which such…
2Cases cited19 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Helvering v. MaytagCourt of Appeals for the Eighth Circuit · 1942
14 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- United States v. Randolph C. Fernon, Jr., Etc. And Susanna F. FernonCourt of Appeals for the Fifth Circuit · 1981
- Shepherd v. CommissionerUnited States Tax Court · 2000
- Chris-Craft Industries, Inc. v. Piper Aircraft Corp.Court of Appeals for the Second Circuit · 1975
- Estate of H. Floyd Sherrod, H. Floyd Sherrod, Jr. And Estalee Sherrod Sandlin, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
20 more not listed; retrieve them via the Exa API.