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MARSHALL NAIFY REVOCABLE TRUST v. U.S.

No. 10-17358.

672 F.3d 620 (2012)

MARSHALL NAIFY REVOCABLE TRUST; Michael Naify, Trustee, successor in interest to the Estate of Marshall Naify, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed February 15, 2012.

Attorney(s) appearing for the Case

G. Michael Halfenger (argued), Foley & Lardner LLP, Milwaukee, WI; Thomas F. Carlucci , Foley & Lardner LLP, San Francisco, CA; Joseph G. Wolberg , Kentfield, CA, for the appellants.

Jennifer M. Rubin , United States Department of Justice, Tax Division/Appellate Section, Washington, D.C., for the appellee.

Before: ARTHUR L. ALARCÓN, CONSUELO M. CALLAHAN, and N. RANDY SMITH, Circuit Judges.

OPINION

ALARCÓN, Senior Circuit Judge:

This is a federal estate tax refund action. Before his death in 2000, Marshall Naify ("Naify") took considerable steps to avoid paying California income tax on $660 million in capital gains.1 After his death, the estate of Marshall Naify ("Estate") deducted $62 million on its federal estate tax return for the estimated amount of California income tax that it might owe on the...

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