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HARTFORD NATIONAL BANK & TRUST CO. v. U.S.

No. 740, Docket 71-1706.

467 F.2d 782 (1972)

The HARTFORD NATIONAL BANK AND TRUST COMPANY, Executor of the Will of Blanche L. Edgar, Deceased, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided August 11, 1972.

Attorney(s) appearing for the Case

Robert W. Marrion, New London, Conn. (John J. McGarry, New London, Conn., of counsel), for plaintiff-appellant.

William M. Brown, Atty., Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Paul M. Ginsburg, Attys., Tax Div., Dept. of Justice, Washington, D. C., and Stewart H. Jones, U.S. Atty., Greenwich, Conn., of counsel), for defendant-appellee.

Before MOORE, SMITH and TIMBERS, Circuit Judges.

MOORE, Circuit Judge:

The Hartford National Bank and Trust Company (Bank), as executor of the will of Blanche L. Edgar, deceased, appeals from a judgment of the United States District Court for the District of Connecticut granting the government summary judgment on the Bank's claim for a refund of federal estate taxes.1 The court below concluded that a split-interest trust created by the decedent's will does not define a standard governing...

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