ESTATE OF O'CONNELL v. C. I. R.

No. 79-7090.

640 F.2d 249 (1981)

ESTATE OF J. E. O'CONNELL, James O'Connell, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 20, 1981.


Attorney(s) appearing for the Case

James E. Merritt (argued), Benjamin J. Delancy, Morrison & Foerster, San Francisco, Cal., on brief for petitioner-appellant.

George L. Hasting, Jr., Washington, D. C., argued for respondent-appellee; Gilbert E. Andrews, Washington, D. C., on brief.

Before SNEED and ANDERSON, Circuit Judges, and EAST, District Judge.


SNEED, Circuit Judge:

This case involves a dispute over the valuation for estate tax purposes of two blocks of stock in close corporations held by the decedent, J. E. O'Connell, at his death. One block is an 80% interest in R. V. Ranch Corporation (R.V.); the other is a 95% interest in Capri Corporation (Capri). The applicable code section is 26 U.S.C. § 2031. The appellant seeks to overturn the valuations fixed by the Tax Court. This court's jurisdiction lies...

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