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Estate of Bright v. United States

658 F.2d 999 (1981)

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Estate of Bright v. United States

United States Court of Appeals for the Fifth Circuit

658 F.2d 999 (1981)

Facts

Mary Frances Smith Bright and her husband together held 55 percent of the stock of several companies as community property. The 55 percent block’s value included a control premium. Bright died, and, pursuant to Texas law, the community property arrangement dissolved. Accordingly, 27.5 percent of the stock went to Bright’s estate (plaintiff). The estate did not account for any control premium when it valued the 27.5 percent block as part of the gross estate. The Internal Revenue Service (IRS) (defendant) audited the estate tax return and assessed a deficiency. The IRS determined that, by application of family-attribution rules, the control premium was still intact and that half of its value was also includable in the gross estate. The estate sued in district court, which ruled in its favor. A panel of the court of appeals vacated the district court. The estate petitioned for a rehearing en banc, which the court of appeals granted.

Rule of Law

Issue

Holding and Reasoning (Anderson, J.)

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