CONNELLY v. UNITED STATES DEP'T OF TREASURY, IRS

No. 21-3683.

70 F.4th 412 (2023)

Thomas A. CONNELLY, in his Capacity as Executor of the Estate of Michael P. Connelly, Sr., Plaintiff-Appellant v. UNITED STATES of America, DEPARTMENT OF TREASURY, INTERNAL REVENUE SERVICE, Defendant-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: June 2, 2023.


Attorney(s) appearing for the Case

Counsel who presented argument on behalf of the appellant, and appeared on the appellant's brief, was Robert L. Devereux , of Frontenac, MO. The following attorney(s) also appeared on the appellant's brief; Steven Andrew Ahillen , of Saint Louis, MO., Jessica A. Gottsacker , of Saint Louis, MO.

Counsel who presented argument on behalf of the appellee, and appeared on the appellee's brief, was Norah Bringer , USDOJ, of Washington, DC. The following attorney(s) also appeared on the appellee's brief; Jennifer Marie Rubin , USDOJ, of Washington, DC.

Before SMITH, Chief Judge, GRUENDER and STRAS, Circuit Judges.


Brothers Michael and Thomas Connelly were the sole shareholders of a corporation. The corporation obtained life insurance on each brother so that if one died, the corporation could use the proceeds to redeem his shares. When Michael died, the Internal Revenue Service assessed taxes...

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