This is an appeal from a district court order granting summary judgment in favor of the defendant benefit plans and company. Plaintiff-appellant alleged that defendants breached their fiduciary duty and their obligation to provide a “full and fair” review of a request for claims when they refuse...   MORE>>

Respondent determined deficiencies in petitioners’ Federal income taxes and penalties as follows:

Penalty

Year Deficiency Sec. 6662(a)

2002 $369,406 $73,881

2003 542,776 108,555

2004 440,850 88,170

The issues for decision are whether petitioners may deduct on Schedule C, Profit o...   MORE>>

Respondent determined a $333,244.59 deficiency in the Federal estate tax of the Estate of Marie J. Jensen (decedent). The issue for decision is the amount of the discount for built-in long-term capital gains tax (LTCG tax) that is allowable in computing the fair market value of the estate’s intere...   MORE>>

In notices of liability dated March 28, 2007, respondent Commissioner of Internal Revenue determined that petitioners, Bruce M. Upchurch (Bruce) and Carl M. Upchurch (Carl), are liable for an estate tax deficiency of $46,758.12, plus interest “as provided by law” up to a total of $53,500 each, a...   MORE>>

Respondent determined a $380,514 deficiency in the Federal estate tax of the Estate of Ralph Robinson (the estate) and a $76,103 accuracy-related penalty under section 6662(a). The estate has conceded the entire deficiency. The sole issue for decision is whether the estate is liable for the accuracy...   MORE>>

Plaintiffs are “native Hawaiians,” defined in section 201(a)of the Hawaiian Homes Commission Act, Pub. L. No. 67-34,42 Stat. 108 (1921) (“HHCA”), to mean “any descendant of not less than one-half part of the blood of the races inhabiting the Hawaiian Islands previous to 1778.” As such th...   MORE>>

Darren Mack murdered his wife, Charla Mack, and shot the state court judge overseeing their divorce proceedings before a final written divorce decree could be filed. Believing Darren Mack and Charla Mack had agreed to the terms of their divorce before Charla Mack’s murder, the Estate of Charla Mac...   MORE>>

A foundation created by Jay Hayden, and the estates of his mother and of another woman (R. Maurine Johnson), brought this RICO suit against a bank, two law firms, and seven persons connected with either the bank or the law firms. The suit charges that the defendants (along with others not named as d...   MORE>>

Appellant The Cadle Company (“Cadle”), the major creditor of the bankruptcy estate of James H. Moore, III (“Moore”), appeals the district court’s affirmance of the bankruptcy court’s approval of a settlement of estate claims over its objection and despite its offer to purchase the claims...   MORE>>

In a letter written on November 13, 1789, Benjamin Franklin famously warned that "in this world nothing is certain but death and taxes." This appeal proves the enduring wisdom of Franklin's pithy admonition. The tale follows.

Refined to bare essence, the appeal presents two interconnected questio...   MORE>>