Legal Opinion
Shriners Hospitals for Crippled Children, as Transferee and Successor in Interest to the Estate of Ernest C. Hudson v. The United States
Court of Appeals for the Federal Circuit
Decided December 13, 1988No. 88-1370PublishedCited by 16 opinions
1Opinion of the Court
PAULINE NEWMAN, Circuit Judge.
Shriners Hospitals for Crippled Children (hereinafter “Shriners”) appeals the judgment of the United States Claims Court, 14 Cl.Ct. 51 (1987), affirming the taxpayer estate’s liability for payment of interest on a tax deficiency assessed prior to retroactive reformation of a testamentary split-interest trust, interpreting 26 U.S.C. § 2055(e)(3) (1984).
We reverse the decision of the Claims Court.
Background
By will of Ernest C. Hudson, who died on February 15, 1979, half of his estate, amounting to $169,569.88, was placed in trust for the benefit of Mrs. Ben Downey…
2Cases cited8 opinions
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- United States v. Koppers Co.Supreme Court of the United States · 1955
- Brown & Williamson, Ltd. v. United StatesUnited States Court of Claims · 1982
- Beneficial Corporation and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- First National Bank v. United StatesUnited States Court of Claims · 1978
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Randall C. Scarborough, Claimant-Appellant v. Anthony J. Principi, Secretary of Veterans AffairsCourt of Appeals for the Federal Circuit · 2003
- J.M. Huber Corp. v. United StatesUnited States Court of Federal Claims · 1993
- Deluxe Corporation v. The United States, Defendant/cross-AppellantCourt of Appeals for the Federal Circuit · 1989
- American Airlines, Inc. v. United StatesUnited States Court of Federal Claims · 2007
- Fluor Corporation and Affiliates v. United StatesCourt of Appeals for the Federal Circuit · 1997
11 more not listed; retrieve them via the Exa API.