Estate of Charles K. McClatchy William K. Coblentz and James McClatchy Personal Representatives v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
1Opinion of the Court
Opinion by Judge TASHIMA; Dissent by Judge D.W. NELSON.
TASHIMA, Circuit Judge:
Appellants (collectively, the “estate”) appeal the Tax Court’s determination of a $1,719,411 deficiency in estate tax due from the estate. The estate contends that the Tax Court incorrectly held that stock owned by the decedent, Charles K. McClatchy (“McClatchy” or “decedent”), should be valued without regard to federal securities law restrictions on marketability that applied to McClatchy during his lifetime, but do not apply to the estate. We have jurisdiction pursuant to 26 U.S.C. § 7482, and we reverse.
I.…
2Cases cited14 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Young Men's Christian Assn. of Columbus v. DavisSupreme Court of the United States · 1924
- 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 Trust Co. v. HelveringSupreme Court of the United States · 1939
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
9 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Morrissey v. CommissionerCourt of Appeals for the Ninth Circuit · 2001
- Bennett v. YoshinaDistrict Court, D. Hawaii · 2000
- Connelly v. United States of America, Department of the Treasury, Internal Revenue ServiceDistrict Court, E.D. Missouri · 2021
- Estate of Charles K. McClatchy William K. Coblentz and James McClatchy Personal Representatives v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- James J. Morrissey v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
1 more not listed; retrieve them via the Exa API.