MANUFACTURERS HANOVER TRUST CO. v. UNITED STATES

No. 1334, Docket 84-6051.

775 F.2d 459 (1985)

MANUFACTURERS HANOVER TRUST COMPANY, as Executor of the Estate of Charlotte C. Wallace, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Second Circuit.

Decided September 16, 1985.


Attorney(s) appearing for the Case

Denny Chin, Asst. U.S. Atty., New York City (Rudolph W. Giuliani, U.S. Atty., Thomas D. Warren, Asst. U.S. Atty., New York City, of counsel), for defendant-appellant.

Robert E. Crotty, New York City (Harvey F. Zimand, Richard J. Concannon, Debra M. Aaron, Kelley Drye & Warren, New York City, of counsel), for plaintiff-appellee.

Isabelle Katz Pinzler, Mary L. Heen, Burt Neuborne, American Civil Liberties Union Foundation, New York City, Steven Shapiro, New York Civil Liberties Union, New York City, submitted a brief for amici curiae American Civil Liberties Union, New York Civil Liberties Union, NOW Legal Defense and Educ. Fund, and Women's Legal Defense Fund.

Before VAN GRAAFEILAND, NEWMAN and PRATT, Circuit Judges.


GEORGE C. PRATT, Circuit Judge:

The question presented in this appeal by the United States from the summary judgment in Manufacturers Hanover Trust Co. v. United States, 576 F.Supp. 837 (S.D.N.Y.1983), Charles E. Stewart, Judge, is whether the Internal Revenue Service's use of gender-based mortality tables to value reversionary interests of a decedent's estate under 26 U.S.C. § 2037 violates the equal protection...

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