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HOPPER v. GOVERNMENT OF VIRGIN ISLANDS

No. 76-1904.

550 F.2d 844 (1977)

Inslee A. HOPPER as Executor of the Estate of Gertrude Thomas Gardner, Deceased, Appellant, v. GOVERNMENT OF the VIRGIN ISLANDS, and Reuben Wheatley, Commissioner of Finance. ESTATE of John Livingston THOMAS, by William W. Bailey, Executor v. Reuben B. WHEATLEY, Commissioner of Finance.

United States Court of Appeals, Third Circuit.

Decided February 8, 1977.

Attorney(s) appearing for the Case

William A. Pallme, Pallme, Anduze, Mitchell & Dow, Charlotte Amalie, St. Thomas, Virgin Islands, for appellant Inslee A. Hopper.

Paul B. Kertman, Asst. Atty. Gen., Dept. of Law, Christiansted, St. Croix, Virgin Islands, for appellee Leroy A. Quinn.

William W. Bailey, Bailey, Wood & Rosenberg, Charlotte Amalie, St. Thomas, Virgin Islands, for appellee Estate of John Livingston Thomas, deceased.

Before SEITZ, Chief Judge, and GIBBONS and HUNTER, Circuit Judges.

OPINION OF THE COURT

GIBBONS, Circuit Judge.

This appeal concerns the tax status to the beneficiary of payments received from a decedent's estate. Appellant Inslee A. Hopper, as executor of the estate of Gertrude T. Gardner, seeks review of an order of the District Court for the Virgin Islands redetermining a deficiency in the tax paid by decedent Gardner for taxable years 1967 through 1971.1<...

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