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Lyeth v. Hoey

United States Supreme Court
305 U.S. 188 (1938)


After the death of his grandmother in 1931, the petitioner (defendant) was deemed one of several heirs to her estate. The grandmother’s will left small legacies to each of her heirs and left the remainder of her estate, which equaled to over $3,000,000, to the trustees of the Endowment Trust. The grandmother’s heirs contested the will in probate court, alleging lack of testamentary capacity and undue influence. Before a jury could hear the case, the parties entered into a compromise agreement by which the bequest to the Endowment Fund was invalidated. Under the terms of the compromise agreement, the heirs received $200,000, the Endowment Fund received $200,000, and the heirs and the trustees of the Endowment Fund equally divided the remainder of the estate. The probate court approved the compromise agreement and the petitioner received his share of the estate in 1933. The Commissioner valued the petitioner’s share at $141,484.03 and deemed it income. The petitioner paid a $56,389.65 tax on the amount and subsequently filed a claim for a refund. The claim was rejected. The petitioner then brought suit in the District Court, which held in his favor. The Court of Appeals, relying on Massachusetts inheritance law, reversed. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Hughes, C.J.)

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