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CITIZENS & SOUTHERN NATIONAL BANK v. UNITED STATES

No. 31121.

451 F.2d 221 (1971)

The CITIZENS & SOUTHERN NATIONAL BANK, as Administrator and John L. Burge, as Executor, Estate of Chester A. Burge, Deceased, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

November 10, 1971.

Attorney(s) appearing for the Case

J. Rene Hawkins, Benjamin M. Garland, T. Reese Watkins, Wilbur D. Owens, Jr., Macon, Ga., for plaintiffs-appellants; Bloch, Hall, Hawkins & Owens, Harris, Russell & Watkins, Macon, Ga., of counsel.

Wm. Schloth, U. S. Atty., D. L. Rampey, Jr., Atty., Macon, Ga., Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Michael L. Paup, Elmer J. Kelsey, Virginia M. Hopkinson, Attys., Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before GEWIN, GOLDBERG, and DYER, Circuit Judges.

GOLDBERG, Circuit Judge:

In this tax dispute we have been summoned to interpret the estate tax marital deduction. While simple in concept, that provision has become more complex with each encrusting precedent. The taxpayers herein seek further complication of that encrustation, requesting this Court to incorporate into the marital deduction provisions the law guiding quilled conveyances of medieval times. However, tax provisions...

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