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ARMSTRONG v. U.S.

No. Civ.A. 96-00100-H.

7 F.Supp.2d 758 (1998)

Frank ARMSTRONG, III, et al., Plaintiffs, v. UNITED STATES of America, Jefferson National Bank, Defendants. UNITED STATES of America, Defendant and Third-Party Plaintiff, v. Frank ARMSTRONG, Jr. Trust for the Benefit of Frank Armstrong, Jr., et al, Third-Party Defendants.

United States District Court, W.D. Virginia, Harrisonburg Division.

May 26, 1998.

Attorney(s) appearing for the Case

Charles S. McCandlish, Harrison & Johnston, Winchester, VA, for Plaintiffs.

Charles S. McCandlish, Harrison & Johnston, Winchester, VA, Aubrey J. Owen, Owen & Truban, Winchester, VA, for Frank Armstrong, III, Trustee of the Frank Armstrong, Jr. Trust for the benefit of Frank Armstrong, Jr., Estate of Frank Armstrong, Jr., Frank Armstrong, III, Executor of Estate of Frank Armstrong, Jr.

Julie C. Dudley, U.S. Atty's Office, Roanoke, VA, Angelo Frattarelli, Washington, DC, U.S. Dept. of Justice, for U.S.

MEMORANDUM OPINION

MICHAEL, Senior District Judge.

I. Background

This case comes before the court following a labyrinthine chain of events. In many ways, the case illuminates the arcane and convoluted nature of the Internal Revenue Code, forcing a recognition of the challenging — and somber — task of integrating and reconciling a multitude of the provisions of that and other...

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