No. 23-146

Thomas A. Connelly, as Executor of the Estate of Michael P. Connelly, Sr. v. United States

Lower Court: Eighth Circuit
Docketed: 2023-08-16
Status: Judgment Issued
Type: Paid
Amici (3)Relisted (2) Experienced Counsel
Tags: closely-held-corporation closely-held-corporations corporate-asset corporate-assets estate-tax federal-estate-tax life-insurance shareholder-redemption tax-valuation valuation
Key Terms:
JusticiabilityDoctri
Latest Conference: 2023-12-08 (distributed 2 times)
Question Presented (AI Summary)

Whether the proceeds of a life-insurance policy taken out by a closely held corporation on a shareholder in order to facilitate the redemption of the shareholder's stock should be considered a corporate asset when calculating the value of the shareholder's shares for purposes of the federal estate tax

Question Presented (OCR Extract)

QUESTION PRESENTED Closely held corporations often enter into agreements requiring the redemption of a shareholder’s stock after the shareholder’s death in order to preserve the closely held nature of the business. Corporations that enter such agreements often purchase life insurance on the shareholder in order to fund the transaction. The question presented is: . Whether the proceeds of a life-insurance policy taken out by a closely held corporation on a shareholder in order to facilitate the redemption of the shareholder’s stock should be considered a corporate asset when calculating the value of the shareholder’s shares for purposes of the federal estate tax. )

Docket Entries

2024-08-22
Record returned to the United States Court of Appeals for the Eighth Circuit.
2024-07-08
Judgment Issued.
2024-06-06
Adjudged to be AFFIRMED. Thomas, J., delivered the <a href = 'https://www.supremecourt.gov/opinions/23pdf/23-146_i42j.pdf'>opinion</a> for a unanimous Court.
2024-03-27
Argued. For petitioner: Kannon K. Shanmugam, Washington, D. C. For respondent: Yaira Dubin, Assistant to the Solicitor General, Department of Justice, Washington, D. C
2024-03-15
2024-02-28
2024-02-27
2024-02-23
Brief of respondent United States filed. (Distributed)
2024-02-14
CIRCULATED
2024-02-07
Record received from the United States Court of Appeals for the Eighth Circuit (1 box) and available with the Clerk.
2024-01-31
Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed.
2024-01-31
Record requested from the United States Court of Appeals for the Eighth Circuit.
2024-01-29
SET FOR ARGUMENT on Wednesday, March 27, 2024.
2024-01-24
Joint appendix filed. (Statement of costs filed)
2024-01-24
2023-12-13
Petition GRANTED.
2023-12-01
DISTRIBUTED for Conference of 12/8/2023.
2023-12-01
Rescheduled.
2023-11-14
2023-11-14
DISTRIBUTED for Conference of 12/1/2023.
2023-10-30
Brief of respondent Internal Revenue Service in opposition filed.
2023-10-02
Motion to extend the time to file a response is granted and the time is further extended to and including October 30, 2023.
2023-09-29
Motion to extend the time to file a response from October 16, 2023 to October 30, 2023, submitted to The Clerk.
2023-09-11
Motion to extend the time to file a response is granted and the time is extended to and including October 16, 2023.
2023-09-07
Motion to extend the time to file a response from September 15, 2023 to October 16, 2023, submitted to The Clerk.
2023-08-15
Petition for a writ of certiorari filed. (Response due September 15, 2023)

Attorneys

Adam Chodorow
Adam Stanton Chodorow — Amicus
Brant Hellwig
Brant James HellwigNew York University School of Law, Amicus
Chamber of Commerce of the United States of America, et al.
Jonathan Charles BondGibson, Dunn & Crutcher LLP, Amicus
Thomas Connelly
Kannon K. ShanmugamPaul, Weiss, Rifkind, Wharton & Garrison LLP, Petitioner
United States
Elizabeth B. PrelogarSolicitor General, Respondent