Supreme Court Rules 9–0 for IRS, Denying Refund in Estate Tax Dispute

Published on June 9, 2024

The Supreme Court ruled unanimously in favor of the IRS on June 6 in a dispute over tax on shareholders’ life insurance policies. Justice Clarence Thomas wrote the court’s 9–0 decision in Connelly v. Internal Revenue Service. The case concerns two brothers’ closely-held corporation. After one of the brothers died, tax authorities and the estate did not agree on the value of the stock. Closely-held corporations commonly enter into agreements that require the redemption of a shareholder’s stock after the shareholder dies to preserve the closely held nature of the business. Under such routine estate-planning devices, corporations that enter into such agreements purchase life insurance on the shareholder to make sure the transaction is funded....

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