Legal Opinion
Looney v. United States
District Court, M.D. Georgia
Decided September 13, 1983No. Civ. A. 81-20-ATHPublishedCited by 2 opinions
1Opinion of the Court
ORDER
OWENS, Chief Judge.
This is a civil action for a refund of estate taxes paid by plaintiff, Joyce B. Looney, as Executrix of the Estate of William J. Brown. At issue is whether survivor benefits payable by a company to its deceased employee’s widow are taxable under section 2039(a) of the Internal Revenue Code as part of the deceased employee’s estate because the deceased employee during his lifetime had contingent, future rights to disability benefits while employed.
Presently before the court are the parties’ cross-motions for summary judgment. The parties having agreed upon a stipula…
2Cases cited5 opinions
- United States Trust Co. v. HelveringSupreme Court of the United States · 1939
- Estate of J. William Bahen, Deceased, Kathleen Privett Bahen, Sole v. The United StatesUnited States Court of Claims · 1962
- Beal v. CommissionerUnited States Tax Court · 1966
- Broderick v. KeefeCourt of Appeals for the First Circuit · 1940
- Estate of William v. Schelberg, Sarah J. Schelberg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
3Cited by2 opinions
- Estate of Rosenberg v. CommissionerUnited States Tax Court · 1986
- Estate of Rosenberg v. CommissionerUnited States Tax Court · 1986