UNITED STATES v. 269 ACRES, MORE OR LESS, LOCATED

Nos. 19-2212, 20-1226, 20-1281.

995 F.3d 152 (2021)

UNITED STATES of America, Plaintiff-Appellant, v. 269 ACRES, MORE OR LESS, LOCATED IN BEAUFORT COUNTY, State of SOUTH CAROLINA; Harold E. Trask, Jr.; John Donald Trask; James Heide Trask; Margaret Scheper Trask; William D. Trask, Jr., as Trustee of the William D. Trask, Jr. Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; Sarah T. Burrus, as Trustee of the Sarah T. Burrus Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; Robert Edward L. Holt, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust-Marital both under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; Robert Edward L. Holt, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust (EI#26-6501159) under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; South Carolina Department of Revenue, Defendants-Appellees, and Beaufort County Assessor; Internal Revenue Service, Defendants. United States of America, Plaintiff-Appellant, v. 269 Acres, More or Less, Located in Beaufort County, State of South Carolina; Harold E. Trask, Jr.; John Donald Trask; James Heide Trask; Margaret Scheper Trask; William D. Trask, Jr., as Trustee of the William D. Trask, Jr. Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; Sarah T. Burrus, as Trustee of the Sarah T. Burrus Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; Robert Edward L. Holt, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust-Marital both under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; Robert Edward L. Holt, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust (EI#26-6501159) under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; South Carolina Department of Revenue, Defendants-Appellees, and Beaufort County Assessor; Internal Revenue Service, Defendants. United States of America, Plaintiff-Appellee, v. 269 Acres, More or Less, Located in Beaufort County, State of South Carolina; Harold E. Trask, Jr.; John Donald Trask; James Heide Trask; Margaret Scheper Trask; William D. Trask, Jr., as Trustee of the William D. Trask, Jr. Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; Sarah T. Burrus, as Trustee of the Sarah T. Burrus Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; Robert Edward L. Holt, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust-Marital both under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; Robert Edward L. Holt, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust (EI#26-6501159) under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004, Defendants-Appellants, and Beaufort County Assessor; South Carolina Department of Revenue; Internal Revenue Service, Defendants.

United States Court of Appeals, Fourth Circuit.

Decided: April 16, 2021.


Attorney(s) appearing for the Case

ARGUED: Jeffrey Steven Beelaert , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellant/Cross-Appellee. Paul Allen Dominick , NEXSEN PRUET, LLC, Charleston, South Carolina, for Appellees/Cross-Appellants. ON BRIEF: Jeffrey Bossert Clark , Assistant Attorney General, Eric Grant , Deputy Assistant Attorney General, Daniel W. Kastner , Richard McMurtray , Environment and Natural Resources Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Peter M. McCoy, Jr. , United States Attorney, Columbia, South Carolina, Lee E. Berlinsky , Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellant/Cross-Appellee. Alexandra H. Austin , NEXSEN PRUET, LLC, Charleston, South Carolina, for Appellees/Cross-Appellants.

Affirmed in part and reversed in part by published opinion. Judge Richardson wrote the opinion, in which Judge King and Judge Wynn joined.


Deference to a district court's factual findings is vital to our judicial system. Our deference respects the superior competence of local fact finders in reviewing the evidence while also promoting judicial economy. This appeal turns on that deference.

After a trial before a three-member land commission, a district...

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