# Estate of Fields v. Commissioner: Estate Tax Valuation Appeal

Page: https://stenobird.com/podcast/swear-on-the-stand-7111404/estate-of-fields-v-commissioner-estate-tax-valuation-appeal
Text version: https://stenobird.com/podcast/swear-on-the-stand-7111404/estate-of-fields-v-commissioner-estate-tax-valuation-appeal.md
Podcast: [Swear on the Stand](https://stenobird.com/podcast/swear-on-the-stand-7111404)
Published: 2026-06-16T12:00:00+00:00
Episode link: https://podcasters.spotify.com/pod/show/danielswear/episodes/Estate-of-Fields-v--Commissioner-Estate-Tax-Valuation-Appeal-e3khbem
Audio file: https://anchor.fm/s/fddb5314/podcast/play/121203606/https%3A%2F%2Fd3ctxlq1ktw2nl.cloudfront.net%2Fstaging%2F2026-5-9%2Fa10881f5-739a-73a6-ceca-1501bb1c0c43.m4a
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Duration seconds: 3305

## Resource

This episode is an opinion from the Fifth Circuit Court of Appeals regarding a dispute between the Estate of Anne Milner Fields and the Internal Revenue Service . The court examined whether $17 million in assets transferred into a limited partnership just before the decedent's death should be taxed at their full value or at a discounted partnership rate. Ultimately, the court affirmed the Tax Court's ruling , finding that the transfers lacked a substantial non-tax purpose and were primarily motivated by estate tax avoidance . Because the executor could not prove the arrangement was a bona fide sale , the assets were recaptured into the gross estate at their original market value . Furthermore, the court upheld a 20% negligence penalty , concluding that the significant tax undervaluation was "too good to be true" for a sophisticated executor to accept in good faith.

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## Transcript

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