Legal Opinion
Farmers Trust Co. v. United States
District Court, M.D. Pennsylvania
Decided September 26, 1978No. Civ. A. 76-1339PublishedCited by 2 opinions
1Opinion of the Court
MEMORANDUM
HERMAN, District Judge.
This action arises under the Internal-Revenue Code of 1954 and involves a claim for refund pursuant to 26 U.S.C. § 7422. Jurisdiction to hear this claim is conferred by 28 U.S.C. § 1346(a)(1). The motions now under consideration are cross-motions for partial summary judgment.
The issue to be decided is whether Section 2055 of the Code requires that a charitable deduction be reduced by the maximum amount of possible Pennsylvania state inheritance taxes that could have been incurred upon the exercise of a power of appointment, when the power was not exercised…
2Cases cited7 opinions
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- The Connecticut Bank and Trust Company, of the Estate of Charles A. Hunter v. United StatesCourt of Appeals for the Second Circuit · 1971
- City National Bank and Trust Company of Columbus, Administrator W/w/a of the Estate of Bess M. Kelly, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1963
- City National Bank & Trust Co. of Columbus v. United StatesDistrict Court, S.D. Ohio · 1962
- Estate of Charles A. Brooks. Deceased Peoples First National Bank and Trust Company and A. W. Robertson, Executors v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1958
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Hess Oil Virgin Islands Corp. v. QuinnDistrict Court, Virgin Islands · 1979
- In re the Estate of BushNew York Surrogate's Court · 1984