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Estate of Blount v. Commissioner

428 F.3d 1338 (2005)

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Estate of Blount v. Commissioner

United States Court of Appeals for the Eleventh Circuit
428 F.3d 1338 (2005)

Facts

William Blount and James Jennings were the principal shareholders of Blount Construction Company (company). Blount, Jennings, and the company entered into a buy-sell agreement that required shareholder consent to any transfer of company stock. The agreement also provided that, were either Jennings or Blount to die, the company would be required to purchase the decedent’s stock. Jennings died while the agreement was in effect, and the company purchased his stock. After learning of a terminal-cancer diagnosis, Blount caused the company to agree to amend the agreement. The amended agreement left intact the company’s obligation to purchase Blount’s shares upon his death but fixed the price at $4 million. The fair market value of the shares absent the agreement was approximately $6 or $7 million. Blount died, and his estate (plaintiff) valued the shares at $4 million when including them in Blount’s gross estate. The Internal Revenue Service (IRS) (defendant) determined that the buy-sell agreement should be disregarded for the purposes of valuing Blount’s gross estate and that the shares should have been included at their fair market value. The IRS issued a deficiency, and Blount’s estate sued in the United States Tax Court. The tax court ruled in favor of the IRS, and Blount’s estate appealed.

Rule of Law

Issue

Holding and Reasoning (Birch, J.)

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