Hibernia Bank appealed a decision to deny its refund claim for estate taxes in the case of Celia Tobin Clark's estate. Hibernia acted as a trustee for the estate's testamentary trusts and appointed as the estate's administrator. After paying bequests and estate claims, Hibernia liquidated the mansion and borrowed funds to maintain it. Hibernia claimed a refund of estate taxes and expense deductions for interest payments on four loans. The court disagreed with Hibernia, stating that the interest payments were not necessary or reasonable for estate administration.
Hibernia Bank v. United States (1978)
United States Court of Appeals for the Ninth Circuit
581 F.2d 741
Learn more about this case at https://www.lsd.law/briefs/view/hibernia-bank-v-united-states-20033505
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