United States v. Wells Fargo Bank

485 U.S. 351 (1988)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

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…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

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.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership