UNITED STATES v. HEMME

No. 84-1944.

476 U.S. 558 (1986)

UNITED STATES ET AL. v. HEMME ET AL.

Supreme Court of United States.

Decided June 3, 1986


Attorney(s) appearing for the Case

Albert G. Lauber, Jr., argued the cause for appellants. With him on the briefs for the United States were Solicitor General Fried, Assistant Attorney General Archer, Michael L. Paup, and Ernest J. Brown.

Edward F. Sutkowski argued the cause for appellees. With him on the brief were Dean B. Rhoads and Donald C. Rikli.*


JUSTICE MARSHALL delivered the opinion of the Court.

Appellees, identified as the trustee of the "revocable living trust" of Charles W. Hirschi and transferees of Hirschi's property, seek a refund of $6,000 in estate taxes, on the ground that the Government's interpretation of a statutory transitional rule, enacted to bridge the old and new regimes for the federal taxation of gifts and estates, violates both the statute and the Constitution.

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