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ESTATE OF BRIGHT v. UNITED STATES

No. 78-2221.

619 F.2d 407 (1980)

The ESTATE of Mary Frances Smith BRIGHT, Deceased, by H. R. Bright, Independent Executor, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

June 18, 1980.

Attorney(s) appearing for the Case

M. Carr Ferguson, Asst. Atty. Gen., Philip I. Brennan, Richard W. Perkins, Gilbert E. Andrews, Acting Chief, Tax Div., U. S. Dept. of Justice, Washington, D. C., for the U. S.

Thompson, Knight, Simmons & Bullion, J. W. Bullion, Emily A. Parker, Payne & Spradley, Robert B. Payne, Dallas, Tex., for plaintiff-appellee.

Before VANCE and SAM D. JOHNSON, Circuit Judges, and THOMAS, District Judge.

SAM D. JOHNSON, Circuit Judge:

This is an appeal by the Government from a successful suit in the district court for a refund of over $3 million in federal estate taxes and assessed interest. The only issue before the district court was the fair market value of the interest of the decedent, Mary Frances Smith Bright, in a series of closely held companies. Before her death, decedent and her husband held 55% of the stock in...

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