Legal Opinion

Loyd v. United States

District Court, W.D. Tennessee

Decided August 26, 1970No. Civ. No. 69-177PublishedCited by 7 opinions

1Opinion of the Court

OPINION

ROBERT M. McRAE, Jr., District Judge.

In this case the plaintiff sues for a partial refund of estate tax based upon the disallowance by the Commissioner of Internal Revenue of a deduction taken by the plaintiff in the amount of the value of a charitable remainder interest in a trust, which remainder interest was subject to a life interest with a power of encroachment in favor of an individual beneficiary. The matter was presented to the Court on a motion of the defendant for a judgment on the pleadings.

The defendant contends that the deduction was properly disallowed because a…

2Cases cited5 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
  3. Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
  4. Samuel H. Salisbury, as Under the Will of Ora S. Hitchcock v. United StatesCourt of Appeals for the Second Circuit · 1967
  5. United States v. The Commercial National Bank of Kansas City and the Boatmen's National Bank of St. LouisCourt of Appeals for the Tenth Circuit · 1968

3Cited by7 opinions

  1. Hemphill v. ShoreSupreme Court of Kansas · 2012
  2. National Bank of Commerce of San Antonio v. United StatesDistrict Court, W.D. Texas · 1973
  3. In Re Estate of Harry B. McCoy Jr., Deceased. Norfleet R. Turner and Frank Wilbourn, Jr., Executors v. United StatesCourt of Appeals for the Sixth Circuit · 1975
  4. Dorothy Jordan Loyd, of Estate of Margaret M. Meador, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1971
  5. In Re Estate of McCoyDistrict Court, W.D. Tennessee · 1974

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