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UNITED STATES v. RIGGS NAT. BANK

Civ. A. No. 84-2889.

636 F.Supp. 172 (1986)

UNITED STATES of America, et al., Plaintiffs, v. RIGGS NATIONAL BANK, et al., Defendants.

United States District Court, District of Columbia.

April 30, 1986.

Attorney(s) appearing for the Case

Edward J. Snyder, Richard L. Switzer, Robert Gordon, Tax Div., Dept. of Justice, Washington, D.C., and J. Brian Ferrel, Acting Chief, Civil Trial Section, Central Region, Dept. of Justice, for plaintiffs.

Richard P. Schifter, Steve Krantz, Arnold & Porter, Washington, D.C., for defendants.

MEMORANDUM

FLANNERY, Senior District Judge.

This matter comes before the court on the parties' cross-motions for summary judgment. Oral argument was heard on April 4, 1986. For the reasons set forth below, the government's motion is granted and defendant Riggs National Bank's motion is denied.

I. Background

In her last will and testament, Isabel G. Zantzinger established a trust fund. By the terms of the fund, her three children...

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