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NationsBank of Texas v. United States

269 F.3d 1332 (2001)

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NationsBank of Texas v. United States

United States Court of Appeals for the Federal Circuit

269 F.3d 1332 (2001)

Facts

For several years, the maximum estate-tax rate was 55 percent. On January 1, 1993, part of a law that had been enacted in 1981 finally went into effect and lowered the maximum estate-tax rate to 50 percent. In March 1993, while the 50 percent maximum rate was in effect, Ellen Garwood died with a gross estate valued at approximately $28 million. In August 1993, Congress passed a new law that (1) increased the maximum estate-tax rate to 55 percent going forward and (2) retroactively raised the maximum estate-tax rate to 55 percent for anyone who had died between January 1, 1993, and August 1993 with a taxable estate of more than $3 million. The retroactive portion of the law increased Garwood’s estate’s tax bill by approximately $1.3 million. As the executor of Garwood’s estate, NationsBank of Texas, N.A. (NationsBank) (plaintiff) sought a $1.3 million refund in the United States Court of Federal Claims. NationsBank argued that retroactively applying the new tax-rate law to a previous event was unconstitutional for several reasons, including arguments that the retroactivity violated (1) the constitutional prohibition on ex post facto laws, (2) due-process principles, and (3) equal-protection principles. The Court of Federal Claims ruled that the law’s retroactivity was constitutional and dismissed the complaint. NationsBank appealed to the Federal Circuit.

Rule of Law

Issue

Holding and Reasoning (Rader, J.)

Dissent (Plager, J.)

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