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ESTATE OF BERG v. C.I.R.

No. 91-3198.

976 F.2d 1163 (1992)

ESTATE OF Edgar A. BERG, Deceased; George Unruh, Jr., Elaine Unruh, Co-personal Representatives, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eighth Circuit.

Decided October 5, 1992.

Rehearing Denied November 3, 1992.

Attorney(s) appearing for the Case

Robert Vaaler of Grand Forks, N.D., argued, for petitioners.

Bruce Ellison, Dept. of Justice, of Washington, D.C., argued, for respondent.

Before McMILLIAN, JOHN R. GIBSON and MAGILL, Circuit Judges.

JOHN R. GIBSON, Circuit Judge.

The estate of Edgar A. Berg, by its representatives, appeals from a Tax Court decision sustaining an estate tax deficiency determined by the Commissioner of Internal Revenue and the addition of a ten percent assessment pursuant to 26 U.S.C. § 6660 (1988), a provision which has been repealed since its application in this case. The estate challenges the Tax Court's findings regarding the marketability and minority interest discounts...

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