Court of Appeals for the Second Circuit August 23, 2007, Docket 06-0815-ag (Lead), 06-1132-ag (XAP) (Estate of Thompson v. Commissioner)

DENNIS JACOBS, Chief Judge:

For estate tax purposes, the United States Tax Court (Swift, J.) valued one-fifth of a closely held company at $13.5 million-an amount far above the $1.75 million valuation proffered by the estate of Josephine T.