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ESTATE OF IVERSEN

No. 76-1289.

552 F.2d 977 (1977)

ESTATE of Robert F. IVERSEN, Deceased. PITTSBURGH NATIONAL BANK, agent for John D. Iversen, Executor, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided March 14, 1977.

Attorney(s) appearing for the Case

Robert J. Dodds, III, Reed Smith Shaw & McClay, Pittsburgh, Pa., for Estate of Robert F. Iversen, Deceased, Pittsburgh National Bank, Agent for John D. Iversen, Executor, appellant.

Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Michael L. Paup, Alfred S. Lombardi, Attys., Tax Div., Dept. of Justice, Washington, D. C., for Commissioner of Internal Revenue, appellee.

Before VAN DUSEN and ROSENN, Circuit Judges, and CAHN, District Judge.

OPINION OF THE COURT

CAHN, District Judge.

The Estate of Robert F. Iversen, Deceased, Pittsburgh National Bank, Agent for John D. Iversen, Executor ("Estate"), appeals1 from an Order and Decision of the United States Tax Court imposing a deficiency in federal estate tax payable by the Estate in the amount of $225,446.01. Robert F. Iversen, a resident of Florida, died testate May 24, 1969. By his Will dated December 20, 1966,...

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