Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

After the tax court determined that petitioners failed to report approximately $41.2 million of compensation income that they realized when certain restricted stockholdings that they owned became substantially vested in January 2004, the tax court upheld the Commissioner's decision to impose accuracy-related penalties for negligence and substantial understatement of tax liability, and denied petitioners' post-trial attempt to offset their underreported income with various net operating loss carrybacks.The Fourth Circuit affirmed the tax court, holding that the tax court did not err in holding that petitioners each realized and were required to report $45.7 million of taxable income when their UMLIC S-Corp. stock substantially vested in taxable year 2004. In this case, even if the Surrender Transactions could somehow be seen as rescinding petitioners' employment and compensation agreements with UMLIC S-Corp., the court agreed with the tax court's conclusion that those transactions were totally devoid of economic substance and must be disregarded for federal income tax purposes. The court also held that the tax court did not err in upholding the accuracy-related penalties imposed by the Commissioner. Finally, the court rejected petitioner's claim that the tax court erred in refusing to consider their net operating losses (NOL) carryback claim during post-trial computation proceedings conducted pursuant to Tax Court Rule 155. View "Estate of Arthur E. Kechijian v. Commissioner" on Justia Law

Plaintiff Fleur and her son, Sidney, filed breach of contract claims against Wilmington. A jury determined that defendants breached an agreement to lend money for the acquisition, maintenance, and certain investments relating to life insurance policies obtained for Charlie and his wife, Fleur. The jury awarded $23 million in damages. The district court then determined post-trial that Wilmington breached an agreement to return certain funds to the Estate upon Charlie's death, and ordered Wilmington to return those funds in accordance with the parties' agreement. The court concluded that the district court did not abuse its discretion in admitting an expert's testimony, because plaintiffs' noncompliance with Rule 26 was harmless in the context of the events that transpired. Furthermore, the district court did not abuse its discretion in rejecting Wilmington's Daubert challenge. The court rejected Wilmington's challenges to the sufficiency of the evidence adduced at trial, and affirmed the district court's order requiring Wilmington to return to the Estate the $5 million in collateral payments that Charlie had made. The court affirmed the portion of the damages award representing the net-in-trust shortfall, because that award was not reached against the clear weight of the evidence, and would not result in a miscarriage of justice. Finally, the court held that the jury properly awarded plaintiffs $3.9 million in consequential damages, and that this award was neither contrary to the clear weight of evidence nor one that would cause a miscarriage of justice. Accordingly, the court affirmed the judgment. View "Bresler v. Wilmington Trust Co." on Justia Law

Diane Z. Kirsch assigned her limited interest in the Lee Graham Shopping Center Limited Partnership to the Diane Z. Kirsch Family Trust where the interest was to pass to the Cullen Trust. The Partnership filed suit after Kirsch died, seeking a declaratory judgment that the Partnership Agreement forbids the transfer of the interest to the Cullen Trust. The district court granted summary judgment to the Partnership on all claims. The court affirmed, concluding that the probate exception does not preclude federal court jurisdiction in this case and the case was properly before the district court, and that the Agreement prohibits the transfer of the interest to the Cullen Trust, which benefits a non-family member. The court found that the Agreement unambiguously prohibits gift transfers of interests to non-family members. View "Lee Graham Shopping Ctr. v. Estate of Kirsch" on Justia Law

Plaintiffs appealed the dismissal with prejudice of their Maryland quiet title claim. Where, as here, a property is encumbered by a deed of trust and its release is conditioned on a party's performance under a note, determining who holds title to the property necessarily involves determining whether the party has performed under the note. Therefore, the court could not decouple the questions of plaintiffs' personal liability and the security interest in the property. In this case, plaintiffs are not entitled to the benefits of a quiet title action because they are not authorized by statute to resolve clouds on a legal title which they do not own. Therefore, the court affirmed the district court's dismissal of the complaint with prejudice. The court also held that the district court acted within its discretion in denying plaintiffs leave to amend the complaint. Accordingly, the court affirmed the judgment of the district court.View "Anand v. Ocwen Loan Servicing, LLC" on Justia Law

Debtor transferred her interest in real property to AGC, a corporation wholly owned by her husband. Seven months later, debtor declared bankruptcy and the bankruptcy court concluded that the conveyance was constructively fraudulent. The bankruptcy court found AGC did not prove by clear and convincing evidence that it paid for the property or intended to pay for it on the date of the property's purchase. The bankruptcy court also found that, at the time of the purchase, the parties intended that AGC would serve as the property's tenant, not the property's owner. AGC also did not prove that it intended to own the property on the date of acquisition. Therefore, the bankruptcy court found no justification for a resulting trust. The district court found no fault in the bankruptcy court's findings of fact, but nonetheless reversed. The court reversed the district court insofar as it found a resulting trust to sever debtor's legal and equitable interests in the property. Accordingly, the court vacated the judgment of the district court and remanded for further proceedings.View "Anderson v. Architectural Glass Construction" on Justia Law

Plaintiff-Appellant Waterford Investment Services, Inc. appealed the district court’s ruling that it must arbitrate certain claims that a group of investors brought before the Financial Industry Regulatory Authority (FINRA). The investors alleged in their FINRA claims that they received bad advice from their financial advisor, George Gilbert. The investors named Gilbert, his current investment firm, Waterford, and his prior firm, Community Bankers Securities, LLC (CBS), among others as parties to the arbitration. In response, Waterford filed this suit asking a federal district court to enjoin the arbitration proceedings and enter a declaratory judgment that Waterford need not arbitrate the claims. The district court, adopting the recommendations of a magistrate judge, concluded that because Gilbert was an "associated person" of Waterford during the events in question, Waterford must arbitrate the investors' claims. Upon review of the matter, the Fourth Circuit affirmed, finding that Gilbert was inextricably an "associated person" with Waterford, and that the district court did not abuse its discretion in adopting the magistrate judge's opinion. View "Waterford Investment Services v. Bosco" on Justia Law

Plaintiffs, relatives of a participant of a life insurance plan governed by the Employee Retirement Income Security Act of 1974 ("ERISA"), sued Metropolitan Life Insurance Company ("Metlife") when Metlife awarded life insurance benefits to the participant's husband. At issue was whether Metlife had fulfilled its statutory duty under ERISA by awarding benefits to the husband where the husband was legally separated from the participant at the time of her death and where the husband was also the beneficiary designated in the documents the participant filed with the plan. The court held that Metlife did fulfill its duties under ERISA in light of Kennedy v. Plan Administrator for DuPont Savings & Investment Plan and therefore, by extension, the "plan documents rule."