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ESTATE OF RENO v. C.I.R.

No. 89-2078.

945 F.2d 733 (1991)

ESTATE OF William L. RENO, Jr.; Barbara G. Reno, Executrix, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Virginia Bar Association, Amicus Curiae.

United States Court of Appeals, Fourth Circuit.

Decided September 13, 1991.

As Amended October 24, 1991.

Attorney(s) appearing for the Case

James Laurence Malone, III, McDermott, Will & Emery, Chicago, Ill., argued (Richard L. Dees, on brief), for petitioners-appellants.

Teresa Ellen McLaughlin, Tax Div., U.S. Dept. of Justice, Washington, D.C., argued (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, and Jonathan S. Cohen, on brief), for respondent-appellee.

Thomas E. Spahn, C.L. Dimos and Suzanne W. Doggett, McGuire, Woods, Battle & Boothe, Richmond, Va., for amicus curiae.

Before ERVIN, Chief Judge, RUSSELL, WIDENER, HALL, PHILLIPS, MURNAGHAN, SPROUSE, WILKINSON, WILKINS and NIEMEYER, Circuit Judges, and CHAPMAN, Senior Circuit Judge, sitting en banc.

OPINION

K.K. HALL, Circuit Judge:

Barbara J. Reno, executrix of the estate of her deceased husband, Dr. William L. Reno, appeals an order of the Tax Court upholding a notice of deficiency issued by appellee, the Commissioner of Internal Revenue. We find that Dr. Reno's purported attempt to shift estate taxes from probate to nonprobate assets is impermissible under Virginia probate, property, and tax apportionment law. Accordingly, we reverse.

I...

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