Legal Opinion

Succession of McCord v. Commissioner

Court of Appeals for the Fifth Circuit

Decided September 15, 2006No. 03-60700PublishedCited by 15 opinions

1Opinion of the Court

WIENER, Circuit Judge:

This is an appeal from an adverse opinion and judgment of an 8-judge majority (the “Majority”) of a splintered United States Tax Court. 1 The Petitioners-Appellants (the “Taxpayers”) 2 seek reversal of the Majority’s holdings, which the Taxpayers accurately characterize as:(1) The aggregate fair market value of the Taxpayers’ donated interests in a family limited partnership, McCord Interests, Ltd., L.L.P. (“MIL”) was $9,883,832 instead of the substantially lesser value of $7,369,215 claimed by the Taxpayers on their returns.(2) The Taxpayers’ charitable deductions under…

2Cases cited20 opinions

  1. Bull v. United StatesSupreme Court of the United States · 1935
  2. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  3. Webb v. Investacorp, Inc.Court of Appeals for the Fifth Circuit · 1996
  4. Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
  5. The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981

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3Cited by15 opinions

  1. Palmer Ranch Holdings Ltd v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 2016
  2. Hendrix v. Comm'rUnited States Tax Court · 2011
  3. Griffin v. Habitat for Humanity International, Inc.District Court, N.D. Georgia · 2015
  4. Nelson v. CIRCourt of Appeals for the Fifth Circuit · 2021
  5. Steinberg v. CommissionerUnited States Tax Court · 2013

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