Hughes v. Sun Life Assur. Co. of Canada

KERNER, Circuit Judge.

Plaintiffs brought this action to declare defendants subject to the duty of recompensing plaintiffs for money paid in settlement of a claim for federal estate taxes on account of the transfer of $945,000 by Mary H. Hughes during her lifetime. The case was tried by the court. The court made special findings of fact, rendered its conclusions of law thereon, and entered a decree dismissing plaintiffs’ complaint for want of equity. To reverse the decree, plaintiffs appeal.

The pertinent and controlling facts found by the court and amply supported by the evidence are that on…