United States Fourth Circuit

In tax court's valuation of decedent's partnership interests, decision not to discount value for decedent's lack of "control" over partnership interests was not clear error; application of minority discount is part of the overall factual question of valuation.

Appellate Information

• Argued 02/28/2002
• Decided 04/15/2002
• Published 04/15/2002

Judges

• Before WILKINSON, Chief Judge, and NIEMEYER and MICHAEL, Circuit Judges.

Court

• United States Fourth Circuit

Counsel

• For Appellees:
  
• ARGUED:  Carl Wells Hall, III, Mayer, Brown & Platt, Charlotte, North Carolina, for Appellants.  Joel L. McElvain, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.   ON BRIEF:  Amy R. Murphy, Mayer, Brown & Platt, Charlotte, North Carolina, for Appellants.  Eileen J. O'Connor, Assistant Attorney General, Richard Farber, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.