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TRUST SERVICES OF AMERICA, INC. v. U.S.

No. 88-6069.

885 F.2d 561 (1989)

TRUST SERVICES OF AMERICA, INC.; Toni Brotman Wald, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided September 8, 1989.

Attorney(s) appearing for the Case

Steven W. Parks, Washington, D.C., for defendant-appellant.

George E. Stephens, Jr., Robert S. Span, Paul Hastings, Janofsky & Walker, Los Angeles, Cal., for plaintiffs-appellees.

Before SCHROEDER, FLETCHER and TROTT, Circuit Judges.

TROTT, Circuit Judge:

The United States appeals the district court's judgment that the United States is not entitled to any setoffs against the estate tax refund due Trust Services of America, Inc. and Toni Brotman Wald (collectively "Trust Services") in their capacity as cotrustees of the trust established by Alix Brotman Hodosh's will. The district court based its judgment on the alternative rationales that the United States...

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