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HENRY T. PATTERSON TRUST BY REEVES BANKING v. U.S.

No. 82-3750.

729 F.2d 1089 (1984)

HENRY T. PATTERSON TRUST, by its Trustee, The REEVES BANKING & TRUST COMPANY, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided March 22, 1984.

Attorney(s) appearing for the Case

Steve Frahm, Tax Div., Dept. of Justice (argued), Glenn L. Archer, Michael L. Paup, Washington, D.C., and J. William Petro, Asst. U.S. Atty., Cleveland, Ohio, for defendant-appellant.

Norman S. Buckvar, Benesch, Friedlander, Coplan & Aronoff, Alan Doris (argued), Cleveland, Ohio, for plaintiff-appellee.

Before EDWARDS and KRUPANSKY, Circuit Judges, and PECK, Senior Circuit Judge.

KRUPANSKY, Circuit Judge.

The United States of America appeals the decision of the United States District Court for the Northern District of Ohio, Eastern Division, in favor of plaintiff-appellee Henry T. Patterson Trust (Trust) in this action for a refund of federal income taxes with interest. The Trust, by its Trustee, the Reeves Banking & Trust Company (Reeves), instituted this action for a refund of $115,747.98 in federal income taxes paid by the Trust in...

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