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UNITED STATES v. ESTATE OF PEARCE

No. 73-1012.

498 F.2d 847 (1974)

UNITED STATES of America v. ESTATE of Claude Beresford PEARCE, Appellant, et al.

United States Court of Appeals, Third Circuit.

Reconsidered without oral argument April 11, 1974.

Decided on May 31, 1974.

Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, William A. Friedlander, William M. Brown, Tax Div., Dept. of Justice, Washington, D. C., for appellee; Norman E. Levine, of counsel.

Bruce M. Stargatt, Ben T. Castle, Young, Conaway, Stargatt & Taylor, Wilmington, Del., for appellant; Robert H. Kapp, Hogan & Hartson, Washington, D. C., of counsel.

Before SEITZ, Chief Judge, and KALODNER, VAN DUSEN, ALDISERT, ADAMS, GIBBONS, ROSENN, HUNTER, WEIS and GARTH, Circuit Judges.

OPINION OF THE COURT

Before KALODNER, ALDISERT and GARTH, Circuit Judges.

Reconsidered April 11, 1974 without oral argument.

Before SEITZ, Chief Judge, and KALODNER, VAN DUSEN, ALDISERT, ADAMS, GIBBONS, ROSENN, HUNTER, WEIS and GARTH, Circuit Judges.

GARTH, Circuit Judge.

The sole issue with which we deal here is: is the denial of a motion to quash a sequestration order (issued in accordance with 10 Del.C. § 366

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