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TRENT v. U.S.

Nos. 88-3740, 88-3778.

893 F.2d 846 (1990)

Tara C. TRENT, Executrix of the Estate of Patrick R. Collins, Deceased, Plaintiff-Appellee, Cross-Appellant, v. UNITED STATES of America, Defendant-Appellant, Cross-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided January 11, 1990.

Rehearing Denied February 21, 1990.

Attorney(s) appearing for the Case

Burgess L. Doan (argued) and Marvin L. Martin, Cohen, Todd, Kite & Stanford, Matthew J. Lane, Cincinnati, Ohio, for plaintiff-appellee, cross-appellant.

Thomas R. Jones, U.S. Dept. of Justice, Tax Div., Washington, D.C., Nicholas J. Pantel, Asst. U.S. Atty., Cincinnati, Ohio, Gary R. Allen, Acting Chief, William S. Rose, Jane S. Kimball, Robert A. Bernstein, David I. Pincus, Linda E. Mosakowski (argued), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., for defendant-appellant, cross-appellee.

Before MERRITT, Chief Judge, NELSON, Circuit Judge, and BROWN, Senior Circuit Judge.

BAILEY BROWN, Senior Circuit Judge.

Tara Collins Trent, executrix of the estate of Patrick R. Collins, who died in 1981, seeks a refund of $487,614.38 of federal estate taxes plus interest, which she contends was erroneously assessed and collected by the Internal Revenue Service. It is the contention of the executrix that the net taxable estate is less than is contended by the government because the estate is entitled to a larger alimony deduction than was allowed...

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