A charitable trust that was the residuary beneficiary of a decedent’s estate was not the “prevailing party” in the estate’s litigation against the Internal Revenue Service and the estate was therefore not entitled to collect attorney’s fees after winning its point, the Third Circuit Court of Appeals has affirmed. The estate of A.J. Palumbo settled a dispute with Palumbo’s son and sole heir over the residue of the estate in which the son received $5.6 million and a charitable trust created by Palumbo received $11.7 million. The estate filed a claim for a charitable estate tax deduction with the IRS. When the IRS refused, the estate filed suit in federal court and won. When it sought...