United States v. Wells Fargo Bank
United States Supreme Court
485 U.S. 351 (1988)
- Written by Sharon Feldman, JD
Facts
Congress enacted the Housing Act of 1937 to address a national housing shortage. The act empowered state and local housing authorities to issue tax-free obligations called “project notes.” To stimulate financing of housing projects, § 5(e) of the act made project notes “exempt from all taxation imposed by the United States.” It was assumed that project notes were exempt only from federal income taxes. In 1984, a district court ruled that project notes were also exempt from federal estate taxes. Wells Fargo Bank and other estate executors (the executors) (plaintiffs) sought refunds of the estate taxes the executors had paid on project notes. The internal revenue commissioner denied the refunds, and the executors sued the United States (defendant). The district court ruled that the project notes were exempt from estate taxes. The United States appealed directly to the Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Brennan, J.)
What to do next…
Here's why 832,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
