ADAMS v. U.S.

No. 99-10497.

218 F.3d 383 (2000)

Patricia M. ADAMS; Ronald Mendenhall; Nationsbank of Texas, N.A., Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

July 5, 2000.


Attorney(s) appearing for the Case

William Reeder Cousins, III (argued), Robert Mershon Bolton, Robert Don Collier, Meadows, Owens, Collier, Reed, Cousins & Blau, Dallas, TX, for Plaintiffs-Appellants.

Curtis C. Pett (argued), Richard Bradshaw Farber, U.S. Dept. of Justice, Tax Div., Washington, DC, for Defendant-Appellee.

Before JONES, DUHÉ and WIENER, Circuit Judges.


WIENER, Circuit Judge:

This estate tax case presents a single issue: Whether discounts for lack of control, lack of marketability, and poor portfolio diversity are applicable when appraising the value of an assignee's fractional interest in a Texas general partnership for estate tax purposes. The district court correctly identified the relevant interest of the partnership in question—that of a partner's assignee, not that of a full-fledged partner—but...

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