Municipal Trust and Savings Bank v. United States of America, Intervenor-Appellant

EASTERBROOK, Circuit Judge.

Richard and Leah Unz died in 1977; their estate owes more than $800,000 in taxes. (For simplicity we refer to the “Unz estate” in the singular; a distinction between Leah’s estate and Richard’s becomes necessary later.) Richardson Bradshaw (Brad) Unz, their son and heir, managed to have some of the estate’s property distributed to him without satisfying the estate’s tax obhgation. He resold that property. Now the United States wants to collect the taxes from a remote transferee.

Details of the transactions are not overly important, but some are essential. The Unz…