Legal Opinion
Eugene P. Ruehlmann, of the Estate of Frances Foster Wells, Deceased v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided November 26, 1969No. 19259_1PublishedCited by 14 opinions
1Opinion of the Court
COMBS, Circuit Judge.
At issue is the proper valuation for estate tax purposes of shares in an open-end or mutual fund investment company. The Tax Court upheld the validity of Treasury Regulation § 20.2031-8 (b), which provides that the value shall be the fair market value of a share determined by the public offering price adjusted for any available reduction in price due to a block sale. 50 T.C. 871 (1968). Six judges dissented from the Tax Court’s decision. The taxpayer in his petition for review contends that the regulation is unreasonable and improper.
Shares in open-end investment…
2Cases cited9 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Powers v. CommissionerSupreme Court of the United States · 1941
- United States v. Gordon Simmons and I. v. Simmons, Executors of the Estate of B. Hill SimmonsCourt of Appeals for the Fifth Circuit · 1965
4 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Walter L. Gross, Jr. And Barbara H. Gross (99-2239) Calvin C. Linnemann and Patricia G. Linnemann (99-2257) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2001
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Miami Beach First National Bank v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Maxe Colleen McCorkle Morris v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
9 more not listed; retrieve them via the Exa API.