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FIRST NAT. BANK v. SNEAD

No. 5214.

24 F.2d 186 (1928)

FIRST NAT. BANK OF BIRMINGHAM, ALA., v. SNEAD, Collector of Internal Revenue.

Circuit Court of Appeals, Fifth Circuit.

February 3, 1928.

Attorney(s) appearing for the Case

William B. White and Wm. Douglas Arant, both of Birmingham, Ala. (Bradley, Baldwin, All & White, and Cabaniss, Johnston, Cocke & Cabaniss, all of Birmingham, Ala., on the brief), for plaintiff in error.

Thos. H. Lewis, Jr., Sp. Atty., Bureau of Internal Revenue, of Washington, D. C., and J. S. Franklin, Asst. U. S. Atty., of Birmingham, Ala., for defendant in error.

Before WALKER, BRYAN, and FOSTER, Circuit Judges.

WALKER, Circuit Judge.

The will of James C. Patterson, who died in January, 1923, after directing the payment of certain legacies, left the residue of his estate to his wife, Christina Patterson, and the First National Bank of Birmingham, as joint trustees to pay the income to said Christina Patterson during her life, and, upon her death, to distribute the residue of the trust estate in equal parts to nine named institutions, which were in existence at the time of...

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