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PROVIDENT NAT. BANK v. UNITED STATES

Civ. A. No. 76-2990.

502 F.Supp. 908 (1980)

PROVIDENT NATIONAL BANK, Executor of the Estate of Abram L. Spector and Trustee under Paragraph 12 of the Will of Abram L. Spector v. UNITED STATES of America.

United States District Court, E. D. Pennsylvania.

August 29, 1980.

Attorney(s) appearing for the Case

Roslyn G. Pollack, Cohen, Shapiro, Polisher, Shiekman & Cohen, Philadelphia, Pa., for plaintiff.

John J. McCarthy, Chief Civil Trial Section, Mikal H. Frey, Donald J. Gavin, Dept. of Justice, Washington, D. C., for defendant.

OPINION

HUYETT, District Judge.

I.

The taxpayer, Provident National Bank, executor of the estate of Abram L. Spector, filed this action seeking a refund of Federal estate taxes. Plaintiff asserts in its claim for refund that certain shares bequeathed in favor of the decedent's widow (the widow's shares) were worth more than the $157 per share figure determined by the Internal Revenue Service and that the taxpayer thus was entitled to a greater...

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