Estate of Thompson v. Commissioner

DENNIS JACOBS, Chief Judge:

For estate tax purposes, the United States Tax Court (Swift, J.) valued one-fifth of a closely held company at $13.5 million-an amount far above the $1.75 million valuation proffered by the estate of Josephine T. Thompson (“Estate”) and far below the $32 million valuation proffered by the Commissioner of Internal Revenue (“Commissioner”) — and declined to impose an underpayment penalty against the Estate, principally on the grounds that the Commissioner’s estimate was so high in the other direction and that the valuation issues were fairly debatable. The Court found…