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UNDERWOOD v. UNITED STATES

No. 18505.

407 F.2d 608 (1969)

J. M. UNDERWOOD and Harry B. Brown, Executors of the Estate of Robert Boone Scott, Deceased, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Sixth Circuit.

March 4, 1969.

Attorney(s) appearing for the Case

W. L. Ambrose, Jr., Knoxville, Tenn. (W. L. Ambrose, Jr., John A. Thomas, Knoxville, Tenn., on the brief), for appellants; Ambrose, Wilson, Thomas & Lockridge, Knoxville, Tenn., of counsel.

Elmer J. Kelsey, Dept. of Justice, Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Jeanine Jacobs, Attys., Dept. of Justice, Washington, D. C., John H. Reddy, U. S. Atty., Robert E. Simpson, Asst. U. S. Atty., Knoxville, Tenn., on the brief), for appellee.

Before COMBS, Circuit Judge, McALLISTER, Senior Circuit Judge, and KENT, District Judge.

COMBS, Circuit Judge.

Plaintiffs-appellants, executors of the estate of Dr. Robert Boone Scott, filed this suit, seeking refund of federal estate taxes paid. The executors originally claimed that six legitimate deductions were wrongfully disallowed by the Internal Revenue Service. Four of the deductions were eventually allowed, either through settlement or by the district court's decision. Only the claimed deductions that...

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