ESTATE OF

720 F.2d 1114 83-2 USTC P 13,548 ESTATE OF Ada E. VAN HORNE, Deceased, Robert L. Farmer and Richard R. Cole, Executors, Petitioners-Appellees Cross-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant Cross-Appellee. Nos. 82-7659, 82-7716. United States Court of Appeals, Ninth Circuit. Argued and Submitted Oct. 4, 1983. Decided Nov. 22, 1983. Robert L. Weaver, Forster, Gemmill & Farmer, Los Angeles, Cal., for respondent-appellant. Terry L. Fredricks, Washington, D.C., for petitioners-appellees. On Appeal from the United States Tax Court. Before FARRIS and REINHARDT, Circuit Judges, and WEIGEL * , District Judge. REINHARDT, Circuit Judge: 1 This case concerns the proper method of valuing certain assets and liabilities for estate tax purposes. The tax court, 78 Tax Court 728, determined that under I.R.C. Sec. 2053(a)(3) (1976) the estate is entitled to a deduction for the full date of death actuarial value of a life time spousal support obligation even when the spouse of the decedent dies prior to the filing of the estate tax return. The government appeals. The tax court also determined that the relevant block of shares to be considered for a blockage discount…