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SHACKELFORD v. UNITED STATES

Civ. A. No. 86-0330-A.

649 F.Supp. 1347 (1986)

V.R. SHACKELFORD, Jr., William du Pont III, and David C. Rittenhouse, as Executors of the Will of Marion du Pont Scott, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Virginia, Alexandria Division.

December 16, 1986.

Attorney(s) appearing for the Case

Atwell W. Somerville, Somerville, Moore & Somerville, Orange, Va., James J. Carroll, Holly A. Harrison, Sidley & Austin, Chicago, Ill., for plaintiffs.

John J. McCarthy, Tax Div., Dept. of Justice, Washington, D.C., Henry E. Hudson, U.S. Atty., E.D. of Va., Dennis E. Szybala, Asst. U.S. Atty., Alexandria, Va., for defendant.

MEMORANDUM OPINION

HILTON, District Judge.

This case comes before the Court on stipulated facts in a suit by the executors of the estate of the decedent Marion du Pont Scott for the refund of federal estate taxes in the amount of $22,532,904 plus interest, which plaintiffs allege represents that part of the federal estate tax paid by the estate which is attributable to the inclusion in the value of the taxable estate of 20 "Project Notes" issued by public...

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