Legal Opinion

Shriners Hospitals for Crippled Children v. United States

United States Court of Claims

Decided December 17, 1987No. 379-85TPublishedCited by 2 opinions

1Opinion of the Court

OPINION

WIESE, Judge.

Plaintiff is the successor in interest to a decedent’s estate. In that capacity, it is entitled to a refund of taxes assessed against the estate in 1980. The refund is the result of a retroactive revision in the estate tax provisions dealing with deductions for charitable remainder trusts. While making this revision retroactive, Congress also provided that the Government would not be liable for interest on those resulting refund claims that would otherwise have been barred by the statute of limitations. The issue presented in this suit is whether this restriction on…

2Cases cited8 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Park 'N Fly, Inc. v. Dollar Park & Fly, Inc.Supreme Court of the United States · 1985
  3. United States v. MendozaSupreme Court of the United States · 1984
  4. Commissioner v. BrownSupreme Court of the United States · 1965
  5. Helvering v. HammelSupreme Court of the United States · 1941

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3Cited by2 opinions

  1. Shriners Hospitals for Crippled Children, as Transferee and Successor in Interest to the Estate of Ernest C. Hudson v. The United StatesCourt of Appeals for the Federal Circuit · 1988
  2. Fluor Corp. v. United StatesUnited States Court of Federal Claims · 1996

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