Estate of James A. Elkins, Jr., et al. v. CIR, No. 13-60472 (5th Cir. 2014)Annotate this Case
Petitioners sought review and eventually eliminate the federal estate tax deficiency assessed against the Estate by the Commissioner. The deficiency resulted solely from the Commissioner's disallowance of the "fractional-ownership discount" applied by the Estate in determining the taxable values of decedent's pro rata shares of the jointly stipulated fair market values of 64 original works of art in which decedent owned only fractional interests at his death. The court affirmed and agreed in large part with the Tax Court's underlying analysis and discrete factual determinations, including its rejection of the Commissioner's zero-discount position. The court reversed, however, the Tax Court's analysis that led it not only to reject the quantums of the Estate's proffered fractional ownership discounts but also to adopt and apply one of its own without any supporting evidence. The court held that the taxable values of decedent's fractional interests in the works of art are the net amounts reflected for each on Exhibit B of the Tax Court's opinion. The court affirmed in part, reversed in part, and rendered judgment in favor of petitioners for a refund of taxes overpaid in the amount of $14,359,508.21, plus statutory interest.