Galloway v. United States

492 F.3d 219 (2007)

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Galloway v. United States

United States Court of Appeals for the Third Circuit
492 F.3d 219 (2007)

Facts

James Galloway died, leaving the residuary of his estate to a revocable trust. The trust had four beneficiaries: Galloway’s son (plaintiff), Galloway’s granddaughter, and two charitable organizations. Each beneficiary had an equal one-quarter interest in the trust, which was to fully distribute its assets to the beneficiaries on scheduled dates. If either the son or the granddaughter were to die before the scheduled dates, his or her interest would be divided equally among the remaining beneficiaries. Galloway’s estate claimed a deduction in the amount equal to the value of the two charitable organizations’ interests in the trust. The Internal Revenue Service (IRS) (defendant) disallowed the deduction and refused to issue a refund. The estate sued in district court, which ruled in favor of the IRS. The estate appealed.

Rule of Law

Issue

Holding and Reasoning (Fisher, J.)

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