3rd Circ. Won't Rethink Tax On Interest In $191M Pharma Deal

By Anna Scott Farrell · January 5, 2026, 5:58 PM EST

The Third Circuit declined to reconsider its decision that a pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included...

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Case Information

Case Title

Charles G. Berwind Trust, et al v. Commissioner of Internal Revenue

Case Number

24-2360

Court

Appellate - 3rd Circuit

Nature of Suit

tax court 

Date Filed

July 30, 2024


Case Title

Russell Shappy, Jr., et al v. Commissioner of Internal Revenue

Case Number

24-2362

Court

Appellate - 3rd Circuit

Nature of Suit

tax court 

Date Filed

July 30, 2024


Case Title

Estate of David M. Berwind, et al v. Commissioner of Internal Revenue

Case Number

24-2363

Court

Appellate - 3rd Circuit

Nature of Suit

tax court 

Date Filed

July 30, 2024


Case Title

D. Berwind, Jr., et al v. Commissioner of Internal Revenue

Case Number

24-2364

Court

Appellate - 3rd Circuit

Nature of Suit

tax court 

Date Filed

July 30, 2024