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ESTATE OF GODLEY v. C.I.R.

No. 01-1887.

286 F.3d 210 (2002)

ESTATE OF Fred O. GODLEY, Deceased; Fred D. Godley, Administrator CTA, Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided April 15, 2002.

Attorney(s) appearing for the Case

ARGUED: Carl Wells Hall, III, Mayer, Brown & Platt, Charlotte, North Carolina, for Appellants. Joel L. McElvain, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Amy R. Murphy, Mayer, Brown & Platt, Charlotte, North Carolina, for Appellants. Eileen J. O'Connor, Assistant Attorney General, Richard Farber, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.

Before WILKINSON, Chief Judge, and NIEMEYER and MICHAEL, Circuit Judges.

Affirmed by published opinion. Chief Judge WILKINSON wrote the opinion, in which Judge NIEMEYER and Judge MICHAEL joined.

OPINION

WILKINSON, Chief Judge.

The Estate of Fred O. Godley ("Estate") appeals the decision of the Tax Court valuing Godley's fifty percent interest in five general partnerships and determining an estate tax deficiency of $247,714. The Estate contends that the Tax Court should have applied a minority discount by discounting Godley...

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