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NETSKY v. U.S.

No. 86-1616.

859 F.2d 1 (1988)

William F. NETSKY, as Executor of the Estate of Frank W. Netsky, Deceased, v. UNITED STATES of America, Appellant.

United States Court of Appeals, Third Circuit.

Resubmitted August 29, 1988.

Decided October 12, 1988.

As Amended November 8, 1988.

Attorney(s) appearing for the Case

Roger M. Olsen, Asst. Atty. Gen., Michael L. Paup, Ernest J. Brown, Tax Div., Dept. of Justice, Washington, D.C. (Edward S.G. Dennis, Jr., U.S. Atty., Philadelphia, Pa., of counsel), for appellant.

Morris L. Weisberg, Ian M. Comisky, Samuel N. Rabinowitz, Blank, Rome, Comisky & McCauley, Philadelphia, Pa., for appellee.

Before SLOVITER, STAPLETON and HUNTER, Circuit Judges.

Submitted Under Third Circuit Rule 12(6) July 16, 1987.

Resubmitted Under Third Circuit Rule 12(6) August 29, 1988.

OPINION OF THE COURT

SLOVITER, Circuit Judge.

The only open issue on this appeal is whether this court has jurisdiction to decide the merits of this claim regarding liability for estate taxes in excess of one million dollars which were indisputably owed to the United States. The appellee contends that this matter falls within...

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