Whatever doubt existed as to the amount of discount allowed on corporate stock at death for built-in capital gains tax liability was largely wiped out with a November, 2007, decision by the Eleventh Circuit Court of Appeals in Estate of Jelke III v. Commissioner.1 That case followed earlier Fifth Court of Appeals decisions in 2001 and 2002 which pioneered the idea that the date of death value of corporate stock was properly discounted, dollar-for-dollar, by the amount of built-in capital gain tax liability.2



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