Pickens v. United States
Petition for certiorari denied on March 4, 2024
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."