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No. 23-146October Term 2023Decided Jun 6, 2024

Docket 23-146October Term 2023 (2023–2024)

Connelly v. United States

In a unanimous decision, the Supreme Court held that life insurance proceeds used by a closely held corporation to redeem a deceased shareholder's stock must be included in the corporation's fair market value for federal estate tax purposes.

Case status

Current stage
Decided
Latest event
Decision released Jun 6, 2024
Case AcceptedDec 13, 2023
Arguments HeardMar 27, 2024
Decision ReleasedJun 6, 2024
What it's about

In a unanimous decision, the Supreme Court held that life insurance proceeds used by a closely held corporation to redeem a deceased shareholder's stock must be included in the corporation's fair market value for federal estate tax purposes. The Court determined that the corporation's contractual obligation to redeem the shares is not a liability that offsets the value of those insurance proceeds.

Question presented

Should 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 be considered a corporate asset when calculating the value of the shareholder’s shares for purposes of the federal estate tax?

Case path

United States Court of Appeals for the Eighth Circuit / Decision released Jun 6, 2024

Area

Business and Regulation