Campbell v. United States

This is another chapter in the continuing saga of attempts by the Internal Revenue Service to limit the use of "flower bonds” to pay federal estate taxes. Flower bonds are United States Treasury bonds (1) that were issued a number of years ago at interest rates substantially below current ones and therefore sell significantly below par, but (2) that may be redeemed at par before maturity to pay federal estate taxes. See generally Girard Trust Bank v. United States, 221 Ct. Cl. 134, 136-37 n.1, 602 F.2d 938, 940 n.1 (1979).

In the present case, as in a number of others, the bonds were purchased…