26 U.S.C. § 2057
Repealed. Pub. L. 113–295, div. A, title II, § 221(a)(97)(A), Dec. 19, 2014, 128 Stat. 4051]
[repealed]
Notes of Decisions
Cited in 14
cases, 1932–2014 · leading case: United States v. Carlton, 512 U.S. 26 (1994).
United States v. Carlton, 512 U.S. 26 (1994). “The new provision, codified as 26 U. S. C. § 2057 (1982 ed., Supp. IV), [1] granted a deduction for half the proceeds of "any sale of employer securities by the executor of an estate" to "an employee stock ownership plan.”
Jerry W. Carlton, of the Will of Willametta K. Day v. United States, 972 F.2d 1051 (9th Cir. 1992). “See 26 U.S.C. § 2057 1 (repealed 1989). The result of the ESOP proceeds deduction was to remove half of the estate from the reach of the federal estate tax, to the extent the estate was comprised of money received from the sale of stock to an ESOP.”
John M. Quarty, Pers. Rep. of the Est. of Angele C. Quarty Elizabeth B. Cherne v. United States, 170 F.3d 961 (9th Cir. 1999). “The estate tax provision, codified as 26 U.S.C. § 2057 , granted a deduction for half of the proceeds of “any sale of employer securities by the executor of an estate” to “an employee stock ownership plan [(“ESOP”)].”
Miller v. Johnson Controls, Inc., 296 S.W.3d 392 (Ky. 2009). “" Approximately a year after Carlton's stock transactions, Congress amended 26 U.S.C. § 2057 so that it expressly applied only where the decedent had owned the stock at death.”
Hambleton v. Dep't of Revenue, 335 P.3d 398 (Wash. 2014). “at 28 (quoting former 26 U.S.C. § 2057 (b) (1982 ed. & Supp. IV)).”
Douglas Q. Kitt & Nancy C. Kitt v. United States, 277 F.3d 1330 (Fed. Cir. 2002). “Carlton involved an estate tax provision, codified at 26 U.S.C. § 2057 , providing a deduction for half the proceeds of “any sale of employer securities by the executor of an estate” to “an employee stock ownership plan,” in any estate tax return filed after the effective date…”
Tax Appeal of Alford v. City & Cnty. of Honolulu, 122 P.3d 809 (Haw. 2005). “2d 22 (1994), the Court held that the retroactive application of an amendment to a provision of the federal estate tax statute, 26 U.S.C. § 2057 , limiting the deduction for the proceeds of sales of stock to employee stock-ownership plans, did not violate the Due Process Clause…”
Bertha Paglin Ferman, Etc. v. United States, 993 F.2d 485 (5th Cir. 1993). “See 26 U.S.C. § 2057 . The term “qualified sale” was defined as “any sale of employer securities by the executor of an estate to .”
Ralph D. Furlong & Jacqueline L. Furlong v. Comm'r of Internal Revenue, 36 F.3d 25 (7th Cir. 1994). “A statute enacted in 1986, 26 U.S.C. § 2057 (b), “granted a deduction for half the proceeds of ‘any sale of employer securities by the executor of an estate’ to ‘an employee stock ownership plan.”
Davidovitz v. United States, 58 F.2d 1063 (Ct. Cl. 1932). “…of the Acts of 1924 (26 USCA §§ 1045, 1057 note) and 1926 (26 USCA §§ 1045, 1057); and section 57 of the Act of 1928 (26 USCA § 2057).”
Ferman v. U.S. (5th Cir. 1993). “See 26 U.S.C. § 2057 . The term "qualified sale" was defined as "any sale of employer securities by the executor of an estate to .”
Est. of Artall v. Comm'r, 595 F.3d 605 (5th Cir. 2010). “The Qualified Family-Owned Business Interest Deduction This case turns on the interpretation of § 2057 of the Internal Revenue Code, 26 U.S.C. § 2057 , which provides an estate tax deduction for certain “qualified family-owned business interests” (“QFOBI’s”).”
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