Bank of New York v. United States
Court of Appeals for the Third Circuit
1Opinion of the Court
OPINION OF THE COURT
ADAMS, Circuit Judge.
For purposes of the federal estate tax, there may be deducted claims against the estate that are paid by the estate and which are founded on promises or agreements, provided that such claims were, in the language of section 2053, “contracted bona fide and for an adequate and full consideration in money or money’s worth . . . .”1
This appeal poses the question whether the cost to an estate of settling a claim set forth in a lawsuit brought by third-party donee beneficiaries and grounded on an alleged breach of contract to make mutual and reciprocal wills…
2Cases cited26 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Koshland v. HelveringSupreme Court of the United States · 1936
- Commissioner v. WemyssSupreme Court of the United States · 1945
- United States v. CalamaroSupreme Court of the United States · 1957
- Robinette v. HelveringSupreme Court of the United States · 1943
21 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Andres Iglesias v. The United States of AmericaCourt of Appeals for the Second Circuit · 1988
- Estate of Theodore Thompson, Deceased, Betsy T. Turner v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2004
- Scott Paper Co. v. United StatesDistrict Court, E.D. Pennsylvania · 1996
- Estate of James H. Waters, Jr., Deceased William Roger Waters and John B. McMillan Co-Executors v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
- Lindberg v. United StatesCourt of Appeals for the Tenth Circuit · 1999
26 more not listed; retrieve them via the Exa API.