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CAMPBELL v. UNITED STATES

No. 560-79T.

657 F.2d 1174 (1981)

Remarize D. CAMPBELL, Independent Executrix of the Estate of Lionel L. Campbell, Deceased v. The UNITED STATES.

United States Court of Claims.

August 19, 1981.

Attorney(s) appearing for the Case

Walter P. Zivley, Houston, Tex., attorney of record, for plaintiff; Liddell, Sapp, Zivley, Brown & LaBoon, Houston, Tex., of counsel.

James S. Maxwell, Washington D. C., with whom was Acting Asst. Atty. Gen., John F. Murray, Washington, D. C., for defendant; Theodore D. Peyser and Donald H. Olson, Washington, D. C., of counsel.

Before FRIEDMAN, Chief Judge, and DAVIS and KUNZIG, Judges.

OPINION

FRIEDMAN, Chief Judge:

This is another chapter in the continuing saga of attempts by the Internal Revenue Service to limit the use of "flower bonds" to pay federal estate taxes. Flower bonds are United States Treasury bonds (1) that were issued a number of years ago at interest rates substantially below current ones and therefore sell significantly below par, but (2) that may be redeemed at par before maturity to pay federal estate taxes. See...

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