Estate of Jack Green, John F. Conway v. United States

Because I believe that trusts in this case satisfy the requirements set forth by the Supreme Court in United States v. Estate of Grace, 395 U.S. 316, 89 S.Ct. 1730, 23 L.Ed.2d 332 (1969), I dissent.

I

First, I conclude that the trusts created by Jack and Norma Green were interrelated. The district court held that the trusts in this ease were not substantially similar because each trust named a different granddaughter as beneficiary. Each of the grandparent trustees could act only to benefit one of the granddaughter beneficiaries. The district court held that this differentiation in the…