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DUNN v. C.I.R.

No. 00-60614.

301 F.3d 339 (2002)

Beatrice Ellen Jones DUNN, Deceased, Estate of, Jesse L. Dunn III, Independent Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

August 1, 2002.

Attorney(s) appearing for the Case

John W. Porter (argued), Stephanie Loomis-Price, Baker Botts, Houston, TX, for Petitioner-Appellant.

Karen D. Utiger (argued), Teresa Ellen McLaughlin, Tax Div., Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept of Justice, Charles Casazza, Clerk, U.S Tax Court, Richard W. Skillman, Chief Counsel, IRS, Washington, DC, for Respondent-Appellee.

Before SMITH, DUHÉ, and WIENER, Circuit Judges.

WIENER, Circuit Judge:

The sole issue presented by this appeal from the United States Tax Court (the "Tax Court") is the fair market value of a block of common stock in Dunn Equipment, Inc. ("Dunn Equipment" or the "Corporation") owned by the late Beatrice Ellen Jones Dunn (the "Decedent") on the date of her death (the "valuation date") for purposes of calculating the estate tax owed by Petitioner-Appellant Estate of Beatrice Ellen Jones Dunn, Deceased (the "Estate...

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