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UNITED STATES v. SILVERMAN

No. 78-2169.

621 F.2d 961 (1980)

UNITED STATES of America, Plaintiff-Appellant, v. Dorothy SILVERMAN, Administratrix, Estate of Fred R. Silverman, Deceased, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied August 21, 1980.

Attorney(s) appearing for the Case

Libero Marinelli, Jr., Dept. of Justice, Washington, D. C., for plaintiff-appellant.

A. V. Falcone, Los Angeles, Cal., for defendant-appellee.

Before CHAMBERS, SNEED and ALARCON, Circuit Judges.

SNEED, Circuit Judge:

This case involves a somewhat obscure, but nonetheless important, area lying at a junction of the federal law fixing the manner in which the United States collects estate taxes and the state law governing the probate of decedents' estates. While our resolution of the issues presented by this case does not elate us, we derive some satisfaction from our belief that it is required by Congress.

The United States seeks to reduce its estate...

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