Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal Revenue, Virginia Bar Association, Amicus Curiae

The panel opinion of the majority in Estate of Reno v. Commissioner, 916 F.2d 955 (4th Cir.1990), vacated upon the grant of rehearing en bane, expresses in some detail why, from my standpoint at least, the Tax Court was correct and should have been affirmed. Unfortunately, the Court en banc has reversed the Tax Court, and I respectfully dissent, limiting my discussion to those points raised by the en banc majority’s opinion here. There has been an unfortunate attempt to accomplish the incompatible, to merge federal estate tax law concepts with ideas of state tenancy by the entireties,…