Estate of Martha B. Watts, William Hubert Lindsey, Jr., Petitioner v. Commissioner of Internal Revenue

HILL, Circuit Judge:

FACTS

Martha B. Watts, the decedent in this case, died on December 7, 1978. At the time of her death, she owned a 15% interest in Rosboro Lumber Company (Rosboro), an Oregon general partnership. As of the date of the decedent’s death, Rosboro had been engaged in the wood products industry for over thirty years. It manufactured and sold lumber, plywood, veneer and laminated beams from logs harvested from its own lands and purchased from others. It owned approximately 22,300 acres of timberland, which were located for the most part, in Lane County, Oregon.

The partners in…