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ESTATE OF CARPENTER v. C.I.R.

No. 94-2176.

52 F.3d 1266 (1995)

ESTATE OF Stanley M. CARPENTER, Deceased; William R. Thomas, Administrator, Petitioners-Appellants, v. COMMISSIONER OF THE INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided May 9, 1995.

Attorney(s) appearing for the Case

ARGUED: Addison Vann Irvin, Brown & Bunch, Chapel Hill, NC, for appellants. David Alan Shuster, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee. ON BRIEF: Loretta C. Argrett, Asst. Atty. Gen., Gary R. Allen, David I. Pincus, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee.

Before WIDENER, MICHAEL and MOTZ, Circuit Judges.

Affirmed by published opinion. Judge MOTZ wrote the opinion, in which Judge WIDENER and Judge MICHAEL joined.

OPINION

MOTZ, Circuit Judge:

This appeal involves the widowed beneficiary of a trust created pursuant to her husband's will, who accepted certain funds as part of a settlement agreement after a dispute arose over the terms of the trust. The tax court found that because the widow's interest under the trust was a life estate unaccompanied by...

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