United States v. Jerry W. Carlton (512 U.S. 26)
U.S. Supreme Court · decided June 13, 1994 · Supreme Court Database (Spaeth)
- Citation
- 512 U.S. 26 · 114 S. Ct. 2018
- Decided
- June 13, 1994
- Term
- October Term 1993
- Vote
- 9–0
- Majority author
- Justice Blackmun
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Blackmun delivered the opinion of the Court. In 1987, Congress amended a provision of the federal estate tax statute by limiting the availability of a recently added deduction for the proceeds of sales of stock to employee stock-ownership plans (E SOP’s). Congress provided that the amendment would apply retroactively, as if incorporated in the original deduction provision, which had been adopted in October 1986. The question presented by this case is whether the retroactive application of the amendment violates the Due Process Clause of the Fifth Amendment. I Congress effected major revisions of the Internal Revenue Code in the Tax Reform Act of 1986,100 Stat. 2085. One of those revisions was the addition of a new estate tax provision applicable to any estate that filed a timely return after the date of the Act, October 22, 1986. The new provision, codified as 26 U. S. C. §2057 (1982 ed., Supp. IV), 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.” § 2057(b). In order to qualify for the deduction, the sale of securities had to be made “before the date on which the [estate tax] return . . . [was] required to be filed (including any extensions).” § 2057(c)(1). Respondent Jerry W. Carlton, the executor of the will of Willametta K. Day, deceased, sought to utilize the § 2057…
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