UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 19-2212

UNITED STATES OF AMERICA,

Plaintiff – Appellant,

v. 269 ACRES, MORE OR LESS, LOCATED IN BEAUFORT COUNTY, STATE OF SOUTH CAROLINA; HAROLD E. TRASK, JR.; JOHN DONALD TRASK; JAMES HEIDE TRASK; MARGARET SCHEPER TRASK; WILLIAM D. TRASK, JR., as Trustee of the William D. Trask, Jr. Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; SARAH T. BURRUS, as Trustee of the Sarah T. Burrus Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; ROBERT EDWARD L. HOLT, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust−Marital both under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; ROBERT EDWARD L. HOLT, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust (EI#26−6501159) under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; SOUTH CAROLINA DEPARTMENT OF REVENUE,

Defendants – Appellees, and BEAUFORT COUNTY ASSESSOR; INTERNAL REVENUE SERVICE,

Defendants.

No. 20-1226

UNITED STATES OF AMERICA, Plaintiff – Appellant,

v. 269 ACRES, MORE OR LESS, LOCATED IN BEAUFORT COUNTY, STATE OF SOUTH CAROLINA; HAROLD E. TRASK, JR.; JOHN DONALD TRASK; JAMES HEIDE TRASK; MARGARET SCHEPER TRASK; WILLIAM D. TRASK, JR., as Trustee of the William D. Trask, Jr. Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; SARAH T. BURRUS, as Trustee of the Sarah T. Burrus Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; ROBERT EDWARD L. HOLT, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust−Marital both under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; ROBERT EDWARD L. HOLT, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust (EI#26−6501159) under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; SOUTH CAROLINA DEPARTMENT OF REVENUE,

Defendants – Appellees, and BEAUFORT COUNTY ASSESSOR; INTERNAL REVENUE SERVICE,

Defendants.

No. 20-1281

UNITED STATES OF AMERICA,

Plaintiff – Appellee,

v. 269 ACRES, MORE OR LESS, LOCATED IN BEAUFORT COUNTY, STATE OF SOUTH CAROLINA; HAROLD E. TRASK, JR.; JOHN DONALD TRASK; JAMES HEIDE TRASK; MARGARET SCHEPER TRASK; WILLIAM D. TRASK, JR., as Trustee of the William D. Trask, Jr. Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; SARAH T. BURRUS,

2 as Trustee of the Sarah T. Burrus Trust under Article Nine of the William D. Trask Revocable Trust dated February 17, 2000; ROBERT EDWARD L. HOLT, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust−Marital both under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004; ROBERT EDWARD L. HOLT, III, as Trustee of the Kitty Trask Holt Family Trust and as Trustee of the Kitty Trask Holt Family Trust (EI#26−6501159) under the Last Will and Testament of Kitty Trask Holt dated June 8, 2004,

Defendants – Appellants, and BEAUFORT COUNTY ASSESSOR; SOUTH CAROLINA DEPARTMENT OF REVENUE; INTERNAL REVENUE SERVICE,

Defendants.

Appeals from the United States District Court for the District of South Carolina, at Beaufort. Richard M. Gergel, District Judge. (9:16-cv-02550-RMG)

Argued: December 10, 2020 Decided: April 16, 2021

Before KING, WYNN, a