No. 23A311
Madeleine Pickens v. United States
Tags: estate-tax-liability last-antecedent-canon personal-liability section-6324 statutory-interpretation trust-beneficiary
Latest Conference:
N/A
Question Presented (from Petition)
Whether Section 6324(a)(2) of the Internal Revenue Code imposes personal liability for unpaid estate taxes on individuals who received estate property at any time after the decedent's death, or only on individuals who received estate property immediately upon the date of the decedent's death.
Question Presented (AI Summary)
Whether 26 U.S.C. § 6324(a)(2) imposes personal liability for unpaid estate taxes on individuals who receive estate property at any time after the decedent's death, or only on those who received property immediately upon the date of the decedent's death
Docket Entries
2023-10-10
Application (23A311) granted by Justice Kagan extending the time to file until November 22, 2023.
2023-10-05
Application (23A311) to extend the time to file a petition for a writ of certiorari from October 23, 2023 to November 22, 2023, submitted to Justice Kagan.
Attorneys
Madeleine Pickens
Neal Kumar Katyal — Hogan Lovells US LLP, Petitioner
United States
Elizabeth B. Prelogar — Solicitor General, Respondent