United States Fifth Circuit

In determining the value of property, the district court cannot make assumptions about the use a hypothetical buyer might have for the property or whether such use would be profitable enough to make up for the tax liability.

Appellate Information

• Decided 09/18/2001
• Published 09/18/2001

Judges

• EDITH H. JONES, Circuit Judge:, Before EDITH H. JONES, DeMOSS and BENAVIDES, Circuit Judges.

Court

• United States Fifth Circuit

Counsel

• For Appellant:
  
• John W. Porter (argued), Seaborn Stacy Eastland, Stephanie Loomis-Price, Baker Botts, Houston, TX, for Petitioners-Appellants.


• For Appellees:
  
• Joan I. Oppenheimer (argued), Gilbert S. Rothenberg, U.S. Dept. of Justice, Tax Div., Charles Casazza, Clerk, U.S. Tax Court, Richard W. Skillman, Chief Counsel, IRS, Claire Fallon, Acting Asst. Atty. Gen., U.S Dept. of Justice, Washington, DC, for Respondent-Appellee.