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ESTATE OF COTTER v. UNITED STATES

Civ. No. 36545.

448 F.Supp. 25 (1977)

ESTATE of Bart COTTER, Deceased, National Bank of Detroit, a National Banking Association, Executor, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Michigan, S. D.

December 13, 1977.

Attorney(s) appearing for the Case

J. Bruce Donaldson, Chirco, Donaldson, Herrinton & Runstadler, Detroit, Mich., for plaintiff.

James K. Robinson, U. S. Atty. by Michele C. Mayes, Asst. U. S. Atty., Detroit, Mich., Claire Fallon, Trial Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM OPINION

THORNTON, District Judge.

This is a civil action for refund of federal estate taxes in the amount of $127,938 and assessed interest of $22,935.95, plus statutory interest. The government has moved for summary judgment and plaintiff has moved for partial summary judgment. The positions of the respective parties have been briefed with thoroughness and oral argument has been had thereon. The underlying...

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