Estate of Lloyd v. United States

The Estate of Norah K. Lloyd (Estate) challenges the Internal Revenue Service’s denial to it of a tax credit under section 2013 of the Internal Revenue Code of 1954, 26 U.S.C. § 2013. That provision grants a full or partial credit for estate taxes paid with respect to the transfer of property *11to a decedent-transferee from a transferor who died within 10 years before or 2 years after the decedent’s death. The issue here is whether a life estate previously willed (in 1970) to Norah K. Lloyd (who died in 1975) was capable of being valued under section 2013. Both sides have moved for summary…