Brown v. United States
Court of Appeals for the Ninth Circuit
1Opinion of the Court
OPINION
BERZON, Circuit Judge:
The estate tax combines into one sad transaction the only two certainties in life. Upon death, a decedent’s estate must pay a tax on property owned immediately prior to death, subject to certain adjustments. 26 U.S.C. § 2001 et seq.1
This appeal involves three of those adjustments. First, we must determine whether the Internal Revenue Service (“IRS”) properly increased the estate tax owed by the estate of Willet Brown (“the Estate”) under § 2035(c)(1993), a provision which increases the estate tax to account for gift taxes paid in the three years immediately prior…
2Cases cited26 opinions
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