Mellon Bank, N.A. v. United States

MAYER, Chief Judge.

Mellon Bank, N.A. and Real Estate Trust (collectively, “Mellon Bank”) appeal the September 18, 2000, judgment of the Court of Federal Claims granting summary judgment to the United States. Mellon Bank, N.A. v. United States, No. 97-CV-151 * (September 18, 2000) (“Mellon II”). Because the Court of Federal Claims properly construed I.R.C. § 67(e)(1), we affirm.

Background

Mellon Bank seeks a consolidated tax refund of income taxes paid in years 1989 through 1992 by thirteen irrevocable trusts created for the benefit of members of the Richard K. Mellon family. Mellon Bank sought…