No. 23-146

Thomas A. Connelly, as Executor of the Estate of Michael P. Connelly, Sr. v. United States

Lower Court: Eighth Circuit
Docketed: 2023-08-16
Status: Judgment Issued
Type: Paid
Amici (3)Relisted (2) Experienced Counsel
Tags: closely-held-corporation closely-held-corporations corporate-asset corporate-assets estate-tax federal-estate-tax life-insurance shareholder-redemption tax-valuation valuation
Latest Conference: 2023-12-08 (distributed 2 times)
Question Presented (from Petition)

Whether the proceeds of a life-insurance policy taken out by a closely held corporation on a shareholder in order to facilitate the redemption of the shareholder's stock should be considered a corporate asset when calculating the value of the shareholder's shares for purposes of the federal estate tax.

Question Presented (AI Summary)

Whether the proceeds of a life-insurance policy taken out by a closely held corporation on a shareholder in order to facilitate the redemption of the shareholder's stock should be considered a corporate asset when calculating the value of the shareholder's shares for purposes of the federal estate tax

Docket Entries

2024-08-22
Record returned to the United States Court of Appeals for the Eighth Circuit.
2024-07-08
Judgment Issued.
2024-06-06
Adjudged to be AFFIRMED. Thomas, J., delivered the opinion for a unanimous Court.
2024-03-27
Argued. For petitioner: Kannon K. Shanmugam, Washington, D. C. For respondent: Yaira Dubin, Assistant to the Solicitor General, Department of Justice, Washington, D. C
2024-03-15
2024-02-28
2024-02-27
2024-02-23
Brief of respondent United States filed. (Distributed)
2024-02-14
CIRCULATED
2024-02-07
Record received from the United States Court of Appeals for the Eighth Circuit (1 box) and available with the Clerk.
2024-01-31
Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed.
2024-01-31
Record requested from the United States Court of Appeals for the Eighth Circuit.
2024-01-29
SET FOR ARGUMENT on Wednesday, March 27, 2024.
2024-01-24
Joint appendix filed. (Statement of costs filed)
2024-01-24
2023-12-13
Petition GRANTED.
2023-12-01
DISTRIBUTED for Conference of 12/8/2023.
2023-12-01
Rescheduled.
2023-11-14
2023-11-14
DISTRIBUTED for Conference of 12/1/2023.
2023-10-30
Brief of respondent Internal Revenue Service in opposition filed.
2023-10-02
Motion to extend the time to file a response is granted and the time is further extended to and including October 30, 2023.
2023-09-29
Motion to extend the time to file a response from October 16, 2023 to October 30, 2023, submitted to The Clerk.
2023-09-11
Motion to extend the time to file a response is granted and the time is extended to and including October 16, 2023.
2023-09-07
Motion to extend the time to file a response from September 15, 2023 to October 16, 2023, submitted to The Clerk.
2023-08-15
Petition for a writ of certiorari filed. (Response due September 15, 2023)

Attorneys

Adam Chodorow
Adam Stanton Chodorow — Amicus
Brant Hellwig
Brant James HellwigNew York University School of Law, Amicus
Chamber of Commerce of the United States of America, et al.
Jonathan Charles BondGibson, Dunn & Crutcher LLP, Amicus
Thomas Connelly
Kannon K. ShanmugamPaul, Weiss, Rifkind, Wharton & Garrison LLP, Petitioner
United States
Elizabeth B. PrelogarSolicitor General, Respondent