Legal Opinion
Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided January 4, 1991No. 89-2078PublishedCited by 5 opinions
1Opinion of the Court
MURNAGHAN, Circuit Judge:
We are called on in the case before us to direct our attention to the interplay between (1) the federal tax code as specifically outlined in the allowance for a marital deduction, (2) the allotment of federal estate tax as directed by Virginia law, (3) the testator’s intent as expressed by will, and (4) Virginia common law property principles concerning property held by husband and wife as a tenancy by the entireties. The question presented is whether a testator, under Virginia law, can direct that part of the federal estate tax due on his gross estate be paid out of…
2Cases cited20 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Tyler v. United StatesSupreme Court of the United States · 1930
- Riggs v. Del DragoSupreme Court of the United States · 1942
- United States v. StapfSupreme Court of the United States · 1964
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3Cited by5 opinions
- Lee Martin, of the Estate of Esther S. Martin and Trustee of the Esther S. Martin Living Trust v. United StatesCourt of Appeals for the Seventh Circuit · 1991
- Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal Revenue, Virginia Bar Association, Amicus CuriaeCourt of Appeals for the Fourth Circuit · 1991
- Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1991
- Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal Revenue, Virginia Bar Association, Amicus CuriaeCourt of Appeals for the Fourth Circuit · 1991
- Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal Revenue, Virginia Bar Association, Amicus CuriaeCourt of Appeals for the Fourth Circuit · 1991