Brigham v. United States
United States Court of Appeals for the First Circuit
160 F.3d 759 (1998)
Facts
Kendal Ham died in 1988. His widow, Anna, elected against Kendal’s will to receive her allotted spousal share rather than the items he had allotted for her. Anna thus was entitled under state law to one-third of the estate remaining after payment of administrative expenses and debts. Accordingly, in 1990 and 1991, Kendal’s executor made payments to Anna. The executor included those payments as distributable net income and took a deduction from the estate’s gross income, while Anna reported and paid income tax on the funds she received. After Anna died, her executor, Paul Brigham, Jr. (plaintiff) filed suit to recover those payments, indicating that payments in satisfaction of Anna’s elective share should have remained income for Kendal’s estate and not been passed to Anna. Brigham argued that Anna, receiving her elective share, should not be considered a beneficiary of Kendal’s estate. He also argued that the payments to Anna were not distributions of income from Kendal’s estate but payments of state-law interests not subject to federal income tax. Meanwhile, the government (defendant) argued that Anna should be considered a beneficiary and be responsible for the tax. The trial court ruled for the government, and Brigham appealed.
Rule of Law
Issue
Holding and Reasoning (Aldrich, J.)
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