Legal Opinion
Marshall Naify Revocable Trust v. United States
Court of Appeals for the Ninth Circuit
Decided February 15, 2012No. 10-17358PublishedCited by 43 opinions
1Opinion of the Court
OPINION
ALARCÓN, Senior Circuit Judge:
This is a federal estate tax refund action. Before his death in 2000, Marshall Naify (“Naify”) took considerable steps to avoid paying California income tax on $660 million in capital gains. 1 After his death, the estate of Marshall Naify (“Estate”) deducted $62 million on its federal estate tax return for the estimated amount of California income tax that it might owe on the $660 million gain if Naify’s California tax avoidance plan failed. The IRS disallowed the deduction. The Marshall Naify Revocable Trust (“Trust”), successor in interest to Naify’s…
2Cases cited20 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- United States v. Benjamin F. Gay Iii, Roy M. PorterCourt of Appeals for the Ninth Circuit · 1992
- Fajardo v. County of Los AngelesCourt of Appeals for the Ninth Circuit · 1999
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- 97 Cal. Daily Op. Serv. 5500, 97 Daily Journal D.A.R. 8912 Jonathan Weisbuch v. County of Los Angeles, a Public Entity and Political Subdivision of the State of California Robert C. Gates Yvonne B. Burke Gloria Molina Edward D. Edelman Michael D. Antonovich Deane DanaCourt of Appeals for the Ninth Circuit · 1997
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3Cited by43 opinions
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- Andrew Salas v. United StatesCourt of Appeals for the Ninth Circuit · 2024
- Universal Trading & Investment Co. v. Dugsbery, Inc.Court of Appeals for the Ninth Circuit · 2012
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