Legal Opinion

ESTATE OF CHARANIA v. Shulman

Court of Appeals for the First Circuit

Decided June 17, 2010No. 09-2430PublishedCited by 3 opinions

1Opinion of the Court

SELYA, Circuit Judge.

In a letter written on November 13, 1789, Benjamin Franklin famously warned that “in this world nothing is certain but death and taxes.” This appeal proves the enduring wisdom of Franklin’s pithy admonition. The tale follows.

Refined to bare essence, the appeal presents two interconnected questions. The first, which concerns the amount of tax due, turns on whether shares of stock held in the name of a decedent were community property under the marital property regime of Belgium (where the decedent and his wife resided when he acquired the shares and when he died) or the…

2Cases cited12 opinions

  1. Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
  2. Ronald Borden v. The Paul Revere Life Insurance Company, Ronald Borden v. The Paul Revere Life Insurance CompanyCourt of Appeals for the First Circuit · 1991
  3. Jeffrey Kassel v. Gannett Co., Inc., D/B/A "Usa Today,"Court of Appeals for the First Circuit · 1989
  4. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
  5. State Police Association of Massachusetts v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1997

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3Cited by3 opinions

  1. Bonterre v. City of New YorkDistrict Court, S.D. New York · 2021
  2. Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
  3. Estate of Jensen v. Comm'rUnited States Tax Court · 2010

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