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CONNECTICUT BANK AND TRUST COMPANY v. UNITED STATES

No. 300, Docket 35122.

439 F.2d 931 (1971)

The CONNECTICUT BANK AND TRUST COMPANY, Executor of the Estate of Charles A. Hunter, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Second Circuit.

Decided March 11, 1971.

Attorney(s) appearing for the Case

S. Michael Schatz, Hartford, Conn. (Schatz & Schatz, Hartford, Conn., and Stanford N. Goldman, Jr., Hartford, Conn., of counsel), for plaintiff-appellee.

Stephen Schwarz, Atty., Tax Division, Dept. of Justice, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Joseph M. Howard, Bennett N. Hollander and Meyer Rothwacks, Attys., Tax Division, Dept. of Justice, Washington, D. C., Stewart H. Jones, U. S. Atty., for the District of Connecticut, and B. Blair Crawford, Asst. U. S. Atty., Hartford, Conn., of counsel), for defendant-appellant.

Before WATERMAN and FRIENDLY, Circuit Judges, and McLEAN, District Judge.

FRIENDLY, Circuit Judge:

The Government's appeal from a judgment of the District Court of Connecticut, 313 F.Supp. 479, in this refund case involves some rather complex provisions of the federal estate tax. Save for a minor addition by way of explanation in the margin,1 we cannot improve upon Judge Clarie's statement of the undisputed facts:

Charles...

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