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NARDI v. UNITED STATES

No. 16171.

385 F.2d 343 (1967)

Victor G. NARDI, as Trustee of the Residuary Trust under the Will of Henrietta S. Seipp, Deceased, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals Seventh Circuit.

October 26, 1967.

Attorney(s) appearing for the Case

Mitchell Rogovin, Asst. Atty. Gen., Tax Div., Karl Schmeidler, Atty., Dept. of Justice, Washington, D. C., Edward V. Hanrahan, U. S. Atty., Chicago, Ill., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., for appellant.

Robert A. Downing, Ira D. Schultz, Maurice J. Miller, Chicago, Ill., Sidley & Austin, Chicago, Ill., of counsel, for appellee.

Before SCHNACKENBERG, CASTLE and FAIRCHILD, Circuit Judges.

SCHNACKENBERG, Circuit Judge.

The United States, defendant, has appealed from a judgment order against defendant, entered by the district court on December 30, 1966 for $100,462.96, plus interest, in favor of plaintiff, Victor G. Nardi, as trustee of the residuary trust under the will of Henrietta S. Seipp, deceased.1 Taxpayer and defendant had each filed a motion for summary judgment.

Henrietta S. Seipp died testate on December...

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