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SCHONGALLA v. HICKEY

Civ. No. 983.

60 F.Supp. 814 (1943)

SCHONGALLA v. HICKEY, U. S. Collector of Internal Revenue.

District Court, N. D. New York.

On Reargument March 20, 1944.

Attorney(s) appearing for the Case

Edward A. Alexander, of New York City (John A. Klett, of New York City, of counsel), for plaintiff.

Ralph L. Emmons, U. S. Atty., of Syracuse, N. Y., Samuel O. Clark, Jr., Asst. Atty. Gen., and Andrew D. Sharpe and Leon F. Cooper, Sp. Assts. to Atty. Gen., for defendant.

BRENNAN, District Judge.

This is an action to recover the sum of $15,594.46, which represents a part of the federal estate taxes levied by reason of the inclusion in the gross estate of the decedent the proceeds of four life insurance policies.

The facts have been stipulated by the attorneys for the respective parties, and the decision rests upon the law applicable thereto.

William Schongalla died on January...

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