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BADGLEY v. U.S.

No. 18-16053.

957 F.3d 969 (2020)

Judith BADGLEY, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed April 28, 2020.

Attorney(s) appearing for the Case

Paul Frederic Marx (argued), Rutan & Tucker LLP, Costa Mesa, California, for Plaintiff-Appellant.

Nathaniel S. Pollock (argued) and Teresa E. McLaughlin , Attorneys; Richard E. Zuckerman , Principal Deputy Assistant General; Tax Division, United States Department of Justice, Washington, D.C.; for Defendant-Appellee.

Before: Carlos F. Lucero, Consuelo M. Callahan, and Bridget S. Bade, Circuit Judges.

OPINION

Thanks to Benjamin Franklin, death and taxes are inextricably linked in most Americans' minds as the only two things in this world that are certain. Thanks to the estate tax, certainty is not the only tie. For the duration of its existence, taxpayers have attempted...

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