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FIRST AMERICAN NATIONAL BANK OF NASHVILLE v. UNITED STATES

Civ. Nos. 2779, 2780.

209 F.Supp. 902 (1962)

FIRST AMERICAN NATIONAL BANK OF NASHVILLE, Executor, et al. v. UNITED STATES of America. Stirton OMAN et ux. v. UNITED STATES of America.

United States District Court M. D. Tennessee, Nashville Division.

August 29, 1962.

Attorney(s) appearing for the Case

William Waller (of Waller, Davis & Lansden), Nashville, Tenn., for plaintiffs.

Kenneth Harwell, U. S. Atty., Nashville, Tenn., and George Hrdlicka, Tax Div., Dept. of Justice, Washington, D. C., for defendant.

GRAY, District Judge.

In 1954, John Oman III, since deceased, and his brother, Stirton Oman, were successful operators of a large business in the heavy construction field with headquarters in Nashville. In that year they undertook to put the Foundation Company, a money-losing New York firm in the same field, back on its feet. Because the Omans were already in high income tax brackets, they made it a condition of their acceptance of management posts that they be granted...

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