Legal Opinion

Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided December 3, 1956No. 15586PublishedCited by 83 opinions

1Opinion of the Court

VAN OOSTERHOUT, Circuit Judge.

The executors of the Estate of Cora R. Fitts, Deceased, have filed a timely petition to review the decision of the Tax Court of the United States placing for estate tax purposes a valuation of $375 per share upon 263% shares of stock in the Fitts Dry Goods Company, hereinafter called Fitts Company, owned by Cora Fitts on the date of her death, February 10,1949. This court has jurisdiction. Internal Revenue Code of 1954, § 7482, 26 U.S.C. § 7482.

The principal issue is whether the Tax Court’s determination of value of the Fitts Company stock is clearly erroneous.…

2Cases cited11 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. Elmhurst Cemetery Co. of Joliet v. CommissionerSupreme Court of the United States · 1937
  4. O'malley, Collector of Internal Revenue v. AmesCourt of Appeals for the Eighth Circuit · 1952
  5. Bank of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1943

6 more not listed; retrieve them via the Exa API.

3Cited by83 opinions

  1. The Sommers Drug Stores Co. Employee Profit Sharing Trust, Cross-Appellant v. Corrigan Enterprises, Inc. And Walter N. Corrigan, Cross-AppelleesCourt of Appeals for the Fifth Circuit · 1986
  2. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
  3. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  4. Messing v. CommissionerUnited States Tax Court · 1967
  5. Estate of Smith v. CommissionerUnited States Tax Court · 1972

78 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API