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Jackson v. United States

376 U.S. 503 (1964)

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Jackson v. United States

United States Supreme Court

376 U.S. 503 (1964)

Facts

George Richards was a resident of California when he died. Under California law, widows were entitled, under certain conditions, to support payments paid out of their husbands’ estates for defined periods of time after a husband’s death. Mrs. Richards (plaintiff), George’s widow, obtained a ruling in state court 14 months after George’s death that she was allowed payments of $3,000 per month for the 24 months following George’s death. Accordingly, Mrs. Richards, the court ruled, was entitled to the $42,000 which had already accrued and could continue receiving $3,000 per month until the 24 months elapsed. Pursuant to California law, Mrs. Richards would cease to be entitled to any future payments if she either remarried or died. Mrs. Richards neither remarried nor died during the 24-month period and received the full $72,000. George’s estate claimed a marital deduction for the support payments, which the Internal Revenue Service disallowed. The estate paid the disputed tax and sued the government (defendant) for a refund in district court. The district court ruled in favor of the government, and the court of appeals affirmed. The United States Supreme Court granted certiorari to hear the estate’s appeal.

Rule of Law

Issue

Holding and Reasoning (White, J.)

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