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Connecticut Bank and Trust Co. v. United States

United States Court of Appeals for the Second Circuit

465 F.2d 760 (1972)

Facts

Four people died in a car accident. Pursuant to state law, the executor of the estates of three of the four people (plaintiff) brought wrongful-death actions on behalf of the decedents. The wrongful-death claims were settled for a substantial amount of money, which the executor did not include in the decedents’ gross estates. The Internal Revenue Service (IRS) (defendant) determined that the settlement proceeds were includable and assessed deficiencies. The executor sued for tax refunds in district court. The district court ruled in favor of the IRS, and the executor appealed.

Rule of Law

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Issue

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Holding and Reasoning (Anderson, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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