Brigham v. United States

160 F.3d 759 (1998)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

Brigham v. United States

United States Court of Appeals for the First Circuit
160 F.3d 759 (1998)

JC

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.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership