Flanders v. United States
United States District Court for the Northern District of California
347 F. Supp. 95 (1972)
- Written by Daniel Clark, JD
Facts
Henry Ottolini owned a one-half interest in a cattle ranch. Ottolini died, and his assets, including his interest in the ranch, were transferred to a trust. Less than a year after Ottolini’s death, the trustee (plaintiff) elected, under a California statute, to dedicate the ranch for public use for a number of years. This election substantially reduced the market value of the ranch. The trustee also elected, pursuant to a federal statute, to have Ottolini’s estate valued on a date a year after his death, rather than on the exact date of his death. The Internal Revenue Service (IRS) (defendant) determined that the decreased value of the ranch due to its dedication for public use should be disregarded for the purpose of valuing the estate. The trustee sued in district court, and the IRS filed for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
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