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Pickens v. United States

Certiorari Denied

Petition for certiorari denied on March 4, 2024.

Docket No.23-571
Op. Below9th Cir.

Issue

Whether under 26 U.S.C. § 6324(a)(2), which imposes personal liability for unpaid estate taxes on any person "who receives, or has on the date of the decedent"s death, [non-probate] property included in the gross estate," the limiting phrase "on the date of the decedent"s death," applies to both the verbs "receives" and "has."

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