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UNITED STATES v. ESTATE OF YOUNG

Civ. A. No. 81-3109.

592 F.Supp. 1478 (1984)

UNITED STATES of America v. ESTATE OF George C. YOUNG, Hannah A. Lawler, Executrix; Helen A. Young; Commonwealth of Pennsylvania, Department of Revenue; and Attorney General, Department of Justice, State of Pennsylvania.

United States District Court, E.D. Pennsylvania.

Amended Order October 19, 1984.

Attorney(s) appearing for the Case

Mark G. Gellar, Trial Atty., Tax Div. U.S. Dept. of Justice, Washington, D.C., Rachel Shao, Asst. U.S. Atty., Philadelphia, Pa., for plaintiff U.S.A.

W. Peter Barnes, Parke, Barnes, Byrne & Spangler, West Chester, Pa., for defendant, Hannah A. Lawler (Ruggiero).

Robert H. Louis, Meltzer & Schiffrin, Philadelphia, Pa., for defendant, Helen A. Young (Gallagher).

Catherine R. Barone, Deputy Atty. Gen., Philadelphia, Pa., for defendant, the Commonwealth of Pa.

OPINION

LUONGO, Chief Judge.

This is an action brought by the government to foreclose its tax lien against real property owned or transferred by the estate of George C. Young. The government has filed a motion for summary judgment, and defendant Helen A. Young (now Gallagher) has responded with a cross-motion for summary judgment and a petition for costs and attorney's fees under the Equal Access to Justice Act. For the reasons

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