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Thomas A. Connelly, as Executor of the Estate of Michael P. Connelly, Sr. v. United States
Paid petition · United States Court of Appeals for the Eighth Circuit, No. 21-3683 · judgment June 2, 2023
Before the decision, about 4.4× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a petition filed soon after the judgment below, and a circuit split argued in the petition.
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.
Counsel of record
For petitioner
Kannon K. Shanmugam
Paul, Weiss, Rifkind, Wharton & Garrison LLP
For respondent
Elizabeth B. Prelogar
Solicitor General
Case
Conference history
Distributed for 2 conferences
Amicus briefs
3 merits
(1 supporting pet./neither, 2 respondent)
Argument & decision
Argued March 27, 2024 — Kannon K. Shanmugam · Yaira Dubin. Audio and transcript
Decided June 6, 2024. Opinion by Thomas.
Proceedings
- Aug 22 2024Record returned to the United States Court of Appeals for the Eighth Circuit.
- Jul 08 2024Judgment Issued.
- Jun 06 2024Adjudged to be AFFIRMED. Thomas, J., delivered the opinion for a unanimous Court.
- Mar 27 2024Argued. For petitioner: Kannon K. Shanmugam, Washington, D. C. For respondent: Yaira Dubin, Assistant to the Solicitor General, Department of Justice, Washington, D. C
- Mar 15 2024Reply of petitioner Thomas Connelly filed. (Distributed)
- Feb 28 2024Brief amicus curiae of Brant Hellwig filed. (Distributed)
- Feb 27 2024Brief amicus curiae of Adam Chodorow filed. (Distributed)
- Feb 23 2024Brief of respondent United States filed. (Distributed)
- Feb 14 2024CIRCULATED
- Feb 07 2024Record received from the United States Court of Appeals for the Eighth Circuit (1 box) and available with the Clerk.
- Jan 31 2024Record requested from the United States Court of Appeals for the Eighth Circuit.
- Jan 31 2024Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed.
- Jan 29 2024SET FOR ARGUMENT on Wednesday, March 27, 2024.
- Jan 24 2024Brief of petitioner Thomas Connelly filed.
- Jan 24 2024Joint appendix filed. (Statement of costs filed)
- Dec 13 2023Petition GRANTED.
- Dec 01 2023Rescheduled.
- Dec 01 2023DISTRIBUTED for Conference of 12/8/2023.
- Nov 14 2023DISTRIBUTED for Conference of 12/1/2023.
- Nov 14 2023Reply of petitioner Thomas Connelly filed. (Distributed)
- Oct 30 2023Brief of respondent Internal Revenue Service in opposition filed.
- Oct 02 2023Motion to extend the time to file a response is granted and the time is further extended to and including October 30, 2023.
- Sep 29 2023Motion to extend the time to file a response from October 16, 2023 to October 30, 2023, submitted to The Clerk.
- Sep 11 2023Motion to extend the time to file a response is granted and the time is extended to and including October 16, 2023.
- Sep 07 2023Motion to extend the time to file a response from September 15, 2023 to October 16, 2023, submitted to The Clerk.
- Aug 15 2023Petition for a writ of certiorari filed. (Response due September 15, 2023)