Robert H. Bachler, of the Estate of E. Murielle Wunderlich v. United States
Court of Appeals for the Ninth Circuit
1Opinion of the Court
OPINION
NOONAN, Circuit Judge.
Robert H. Bachler (“the Executor”), executor of the estate of E. Murielle Wun-derlich, appeals the judgment of the district court for the Northern District of California denying his suit for refund of estate tax erroneously paid pursuant to Internal Revenue Code § 2612(c). We hold that the tax was paid upon a transfer of property by a general power of appointment under a trust that became irrevocable in 1976, and was therefore a generation-skipping transfer exempted by § 1433(b) of the Tax Reform Act of 1986, Pub.L. No. 99-514, 100 Stat.2085, from the…
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