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United States v. Wells Fargo Bank

485 U.S. 351 (1988)

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United States v. Wells Fargo Bank

United States Supreme Court

485 U.S. 351 (1988)

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.)

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