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ESTATE OF BLOUNT v. C.I.R.

No. 04-15013.

428 F.3d 1338 (2005)

ESTATE OF George C. BLOUNT, Deceased, Fred B. Aftergut, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

October 31, 2005.

Attorney(s) appearing for the Case

Sara Lynn Doyle, R. Douglas Wright, Alfred B. Adams, III, Holland & Knight, LLP, Atlanta, GA, for Petitioner-Appellant.

Steven W. Parks, Michelle B. O'Connor, U.S. Dept. of Justice, Tax Div., Jonathan S. Cohen, Dept. of Justice, Washington, DC, for Respondent-Appellee.

Before BIRCH, CARNES and FAY, Circuit Judges.

BIRCH, Circuit Judge:

Confronting the verisimilitude of American life, death and taxes, this appeal asks us to decide a recurring issue of asset valuation for estate tax purposes and whether a stock-purchase agreement meets the requirements of a tax code exception to the general valuation-at-fair-market-value rule. The estate of Blount was required to sell Bount's shares when he died, and Blount's family business owned an insurance policy to ensure that it would have...

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