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UNITED STATES v. BRENNAN

No. 73-1765.

488 F.2d 858 (1974)

UNITED STATES of America, Plaintiff-Appellee, v. F. U. BRENNAN, Executrix of the Estate of William J. Brennan, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

January 25, 1974.

Attorney(s) appearing for the Case

C. V. Stelzenmuller, Birmingham, Ala., for defendant-appellant.

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Atty., Tax Div., Dept. of Justice, Fred B. Ugast, Acting Asst. Atty. Gen., Lee H. Henkel, Jr., Acting Chief Counsel, I.R.S., Washington, D. C., Ira DeMent, U. S. Atty., Kenneth E. Vines, Asst. U. S. Atty., Montgomery, Ala., Murray S. Horwitz, Richard W. Perkins, Atty., Tax Div., Dept. of Justice, Washington, D. C., for plaintiff-appellee.

Before BELL, DYER and CLARK, Circuit Judges.

BELL, Circuit Judge:

This action was instituted by the United States of America against F. U. Brennan, Executrix of the Estate of William J. Brennan, for unpaid Interest Equalization taxes and penalty, amounting to $31,613.50 plus interest as provided by law. The district court entered judgment, see United States v. Brennan, M.D.Ala., 1973, 368 F.Supp. 901, for the full amount in favor of the Government. Appellant contests the...

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