Get more case briefs explained with Quimbee. Quimbee has over 16,300 case briefs (and counting) keyed to 223 casebooks ► [ Ссылка ]

Lyeth v. Hoey | 305 U.S. 188 (1938)

When a person dies, his or her estate will generally be distributed either to beneficiaries under a will or to the person’s heirs under state intestate succession laws if the person dies without a will. In Lyeth versus Hoey, we explore whether a beneficiary or heir faces federal income tax liability for property he or she acquires in such a distribution.

Mary Longyear’s will granted small legacies to each of her six heirs, including her grandson Lyeth, and bequeathed her residuary estate, totaling more than three million dollars, to a trust. Unhappy with their small legacies, the heirs contested the will’s validity, seeking a distribution of Longyear’s estate under the intestate succession statute as if Longyear had died without a will.

Before the will’s validity went to trial before a jury, the heirs, other beneficiaries, and executors reached a settlement agreement. Under that agreement, Longyear’s heirs, including Lyeth, each received a share of Longyear’s residuary estate.

The Commissioner of Internal Revenue valued Lyeth’s share at approximately one hundred forty-one thousand dollars and treated the entire amount as taxable income. Lyeth paid approximately fifty-six thousand dollars in taxes but then claimed that he was entitled to a refund. He argued that he acquired his share of the residuary estate by inheritance, and tax laws exempted property acquired by inheritance from taxation. The commissioner rejected Lyeth’s refund claim, stating that the acquisition of property under a settlement agreement didn’t constitute acquisition by inheritance. Lyeth then filed suit against Hoey, the tax collector.

The district court held in Lyeth’s favor, holding that his share of the residuary estate was acquired by inheritance and therefore exempt from federal income tax. The Second Circuit reversed, and the United States Supreme Court granted cert.

Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here:[ Ссылка ]

The Quimbee App features over 16,300 case briefs keyed to 223 casebooks. Try it free for 7 days! ► [ Ссылка ]

Have Questions about this Case? Submit your questions and get answers from a real attorney here: [ Ссылка ]

Did we just become best friends? Stay connected to Quimbee here: Subscribe to our YouTube Channel ► [ Ссылка ]
Quimbee Case Brief App ► [ Ссылка ]
Facebook ► [ Ссылка ]
Twitter ► [ Ссылка ]
#casebriefs #lawcases #casesummaries

свернуть