Legal Opinion

Estate of Jelke v. Commissioner

Court of Appeals for the Eleventh Circuit

Decided November 15, 2007No. 05-15549PublishedCited by 28 opinions

1Opinion of the Court

HILL, Circuit Judge:

This estate tax case presents on appeal an issue of first impression in this circuit.1 It involves the proper valuation for estate tax purposes of a 6.44% stock interest, or 3,000 shares, owned by the decedent, Frazier Jelke III (Jelke or decedent or estate),2 in a closely-held, investment holding company, Commercial Chemical Company (CCC), owning appreciated, marketable securities.3

The issue is whether or not the Tax Court used the appropriate valuation methodology in computing the net asset value of CCC to determine the value of Jelke’s interest in CCC for estate tax…

2Cases cited30 opinions

  1. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  2. General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
  3. Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
  4. Estate of Andrews v. CommissionerUnited States Tax Court · 1982
  5. Powers v. CommissionerSupreme Court of the United States · 1941

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3Cited by28 opinions

  1. Campbell v. CommissionerCourt of Appeals for the Eleventh Circuit · 2011
  2. Congel v. MalfitanoCourt for the Trial of Impeachments and Correction of Errors · 2018
  3. Curt Daniels Vs. John Holtz Wsh Properties Llc Navajo Associates, Llc, John Does And Jane Roes 1–5Supreme Court of Iowa · 2010
  4. Wechsler v. WechslerAppellate Division of the Supreme Court of the State of New York · 2008
  5. Palmer Ranch Holdings Ltd v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 2016

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