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Estate of Jameson v. Commissioner of Internal Revenue

Although the Tax Court is not required to credit the valuation testimony of either party, its calculations must be tied to the record and to sound and consistent economic principle.

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As amended October 12, 2001

On Appeal from the United States Tax Court

The Estate of Helen Jameson appeals following a Tax Court decision assessing a deficiency against it. The Estate argues that the Tax Court clearly erred in valuing assets of Johnco, Inc. (“Johnco”), a holding company that is part of the estate. It also raises a plausible but unsustainable constitutional challenge to the estate tax as applied in this case. As we agree that the court’s valuations were in error, we vacate and remand for further proceedings.

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