Connelly v. United States
U.S. Supreme Court · decided June 6, 2024 · Supreme Court Database (Spaeth)
- Decided
- June 6, 2024
- Term
- October Term 2023
- Vote
- 9–0
- Majority author
- Justice Thomas
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
PRELIMINARY PRINT Volume 602 U. S. Part 1 Pages 257–267 OFFICIAL REPORTS OF THE SUPREME COURT June 6, 2024 Page Proof Pending Publication REBECCA A. WOMELDORF reporter of decisions NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D.C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2023 257 Syllabus CONNELLY, as executor of the ESTATE OF CONNELLY v. UNITED STATES certiorari to the united states court of appeals for the eighth circuit No. 23–146. Argued March 27, 2024—Decided June 6, 2024 Michael and Thomas Connelly were the sole shareholders in Crown C Sup- ply, a small building supply corporation. The brothers entered into an agreement to ensure that Crown would stay in the family if either brother died. Under that agreement, the surviving brother would have the option to purchase the deceased brother's shares. If he declined, Crown itself would be required to redeem (i.e., purchase) the shares. To ensure that Crown would have enough money to redeem the shares if required, it obtained $3.5 million in life insurance on each brother. After Michael died, Thomas elected not to purchase Michael's shares, thus triggering Crown's obligation to do so. Michael's son and Thomas agreed that the…
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