Legal Opinion
Hazel S. Wisely, of the Estate of William H. Wisely, Deceased v. United States
Court of Appeals for the Fourth Circuit
Decided January 11, 1990No. 89-2606PublishedCited by 31 opinions
1Opinion of the Court
JAMES C. FOX, District Judge:
This is a suit for the refund of $124,311 in estate taxes, penalties, and interest, assessed and collected by the Internal Revenue Service from the Estate of William H. Wisely. In the district court, judgment was for the United States and the taxpayer estate has appealed. The principal question for our determination is whether the district court properly granted summary judgment for the government in holding that the deceased’s will, as drafted, failed to qualify the marital trust for the marital estate tax deduction under Title 26 U.S.C. § 2056(b)(5). Having…
2Cases cited19 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- White v. United StatesSupreme Court of the United States · 1938
- Estate of Harrison P. Shedd, Deceased First National Bank of Arizona, Phoenix v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
14 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- In Re Landbank Equity Corporation, a Virginia Corporation, Debtor. Internal Revenue Service v. Laurence H. Levy, Trustee, Debera F. ConlonCourt of Appeals for the Fourth Circuit · 1992
- Estate of Nicholson v. CommissionerUnited States Tax Court · 1990
- Canaan National Bank v. PetersSupreme Court of Connecticut · 1991
- Collins Music Company, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1994
- Estate of Ellingson v. CommissionerUnited States Tax Court · 1991
26 more not listed; retrieve them via the Exa API.