Joy B. Patten, Administrator of the Estate of Marjory L. Blaney, Deceased v. United States

Affirmed by published opinion. Judge WILLIAMS wrote the majority opinion, in which Judge WILKINS joined. Judge K.K. HALL wrote a dissenting opinion.

OPINION

WILLIAMS, Circuit Judge:

The United States (the Government) appeals from the district court’s ruling in favor of Joy B. Patten, administrator of the estate of Marjory L. Blaney (Taxpayer). The district court concluded that the effective date of 26 U.S.C. § 2040(b)(2) (1994), did not expressly or impliedly repeal the effective date of 26 U.S.C. § 2040(b)(1) (West 1994), and therefore Patten was entitled to claim a stepped-up basis in a parcel…