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ANTHONY v. U.S.

No. 07-30089.

520 F.3d 374 (2008)

Tincy ANTHONY, Administratrix of the Succession of James Louis Bankston, Sr., on behalf of James Louis Bankston, Sr., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

March 4, 2008.

Attorney(s) appearing for the Case

Walter C. Antin, Jr. (argued), John Gerhardt Toerner, Antin Law Firm, Hammond, LA, for Plaintiff-Appellant.

Francesca Ugolini Tamami, Jonathan S. Cohen (argued), U.S. Dept. of Justice, Tax Div. Appellate Section, Washington, DC, James L. Nelson, Asst. U.S. Atty., Baton Rouge, LA, for Defendant-Appellee.

Before BARKSDALE, DENNIS and SOUTHWICK, Circuit Judges.

SOUTHWICK, Circuit Judge:

A decedent's administratrix seeks our reversal of the district court's conclusion that a non-transferable private annuity must be valued, for estate tax purposes, in accordance with certain tables set out in the Internal Revenue Code. Because we conclude that this case presents no applicable exception to valuation of the relevant annuities by use of the tables, we affirm.

I. FACTS AND PROCEEDINGS

James Louis Bankston, Sr...

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