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BOYLE v. UNITED STATES

No. 15118.

355 F.2d 233 (1965)

James J. BOYLE and Katherine Boyle, His Wife, Annie Egner and Fred Egner, Her Husband, Catherine B. Kip and Edward Kip, Her Husband, Joseph Keane and Hudson County National Bank, Executors of the Estate of Regina T. Boyle, Deceased, James McMahon, James Boyle and Hudson County National Bank, Executors of the Estate of John F. Boyle, Jr., Deceased, Appellants, v. UNITED STATES of America.

United States Court of Appeals Third Circuit.

Decided December 29, 1965.

Rehearing Denied February 3, 1966.

Attorney(s) appearing for the Case

Joseph Keane, Jersey City, N. J., Richard B. Nashel, Newark, N. J. (Milton, Keane & De Bona, Jersey City, N. J., on the brief), for appellants.

Jonathan S. Cohen, Atty., Dept. of Justice, Tax Div., Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney, Attys., Dept. of Justice, Washington, D. C., David M. Satz, Jr., U. S. Atty., Martin Tuman, Asst. U. S. Atty., on the brief), for appellee.

Before McLAUGHLIN, STALEY and SMITH, Circuit Judges.

McLAUGHLIN, Circuit Judge.

Briefly stated, the problem involved is whether or not appellant taxpayers are within the purview of 26 U.S.C. § 691, so as to be entitled to a deduction for estate taxes paid on certain accumulated dividend arrearages which are being declared and paid to taxpayers causing them to become liable for income taxes thereon; or in the alternative does the doctrine of Equitable Recoupment, as set forth in Bull v. United States,

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