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ESTATE OF LLOYD v. UNITED STATES

No. 367-79T.

650 F.2d 1196 (1981)

ESTATE of Norah K. LLOYD v. The UNITED STATES.

United States Court of Claims.

June 3, 1981.

Attorney(s) appearing for the Case

Christopher H. Little, Providence, R. I., attorney of record, for plaintiff.

Edmund C. Bennett, II, Margaret D. Farrell and Tillinghast, Collins & Graham, Providence, R. I., of counsel.

William B. Barker, with whom was Acting Asst. Atty. Gen. John F. Murray, Washington, D.C., for defendant.

Theodore D. Peyser, Jr., and Donald H. Olson, Washington, D.C., of counsel.

Before DAVIS, NICHOLS, and BENNETT, Judges.

ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

DAVIS, Judge:

The Estate of Norah K. Lloyd (Estate) challenges the Internal Revenue Service's denial to it of a tax credit under section 2013 of the Internal Revenue Code of 1954, 26 U.S.C. § 2013. That provision grants a full or partial credit for estate taxes paid with respect to the transfer of property to a decedent-transferee from a transferor who died within 10 years before or 2 years after the decedent's...

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