Legal Opinion

Galloway v. United States

Court of Appeals for the Third Circuit

Decided June 21, 2007No. 06-3007PublishedCited by 8 opinions

1Opinion of the Court

OPINION OF THE COURT

FISHER, Circuit Judge.

This case comes to us on appeal from the decision of the District Court affirming the Internal Revenue Service’s (“IRS”) decision to disallow a nearly $400,000 charitable deduction claimed by the James D. Galloway Revocable Living Trust (“the Trust”). We are asked to determine whether Internal Revenue Code (“IRC”) § 2055(e) prevents an estate from claiming a charitable deduction when distributing the proceeds of a single trust to both charitable and non-charitable beneficiaries. We hold that it does, and, for the reasons set forth below, we will…

2Cases cited15 opinions

  1. Exxon Mobil Corp. v. Allapattah Services, Inc.Supreme Court of the United States · 2005
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  4. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  5. United States v. MerriamSupreme Court of the United States · 1923

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3Cited by8 opinions

  1. Conopco, Inc. v. United StatesCourt of Appeals for the Third Circuit · 2009
  2. Harvard Secured Creditors Liquidation Trust v. Internal Revenue Service (In Re Harvard Industries, Inc.)Court of Appeals for the Third Circuit · 2009
  3. Bayer Corp. & Subsidiaries v. United StatesDistrict Court, W.D. Pennsylvania · 2012
  4. CHAIRES v. NOVO NORDISK INC.District Court, D. New Jersey · 2021
  5. Harvard Secured Creditors Liquidation Trust v. Internal Revenue ServiceCourt of Appeals for the Third Circuit · 2009

3 more not listed; retrieve them via the Exa API.

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