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P was the grandson of Mary who died in 1931. By her will, Mary gave to her heirs certain small legacies and the entire residual estate was left to trustees in an Endowment Trust. That trust was created in 1926, and the income from it was payable to another trust called the Longyear Foundation. The main purpose of the Longyear Foundation was to preserve the records of the earthly life of Mary Baker Eddy, the founder of the Christian Science Religion. There immediate objections to the will when it was probated were lack of testamentary capacity and undue influence. A compromise settlement was eventually reached between the parties. This compromise was approved by the court, and a decree was entered in 1932. The IRS eventually got involved and deemed this settlement to be a contract and as such taxes were due. The District Court entered summary judgment, and the Court of Appeals reversed.

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