The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United States

R. LANIER ANDERSON, III, Circuit Judge:

This case presents to the en banc court an important question involving the principles of federal estate tax valuation. . Mary Frances Smith Bright died on April 3, 1971. During her lifetime, she and her husband, Mr. Bright, owned 55% of the common stock of East Texas Motor Freight Lines, Inc., 55% of the common stock of twenty-seven affiliated corporations, and 55% of the common and preferred stock of Southern Trust and Mortgage Company (the stock of all such corporations is hereinafter referred to collectively as the “stock”).

During her lifetime, Mr.…