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ESTATE OF O'DANIEL v. U.S.

No. 92-2493.

6 F.3d 321 (1993)

ESTATE OF Finis A. O'DANIEL, Deceased, Keith A. O'Daniel, and Deborah N. Cantrell, Co-Executors, Plaintiffs-Appellees, Cross-Appellants, v. UNITED STATES of America, Defendant-Appellant, Cross-Appellee.

United States Court of Appeals, Fifth Circuit.

November 9, 1993.

Attorney(s) appearing for the Case

Robert I. White, Linda S. Paine, Chamberlain, Hrdlicka, White, Williams & Martin, Houston, TX, for plaintiffs-appellees, cross-appellants.

Greg Garland, Dept. of Justice, Dallas, TX, Robert W. Metzler, Jonathan S. Cohen, Gary R. Allen, U.S. Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for defendant-appellant, cross-appellee.

Before GARWOOD, DAVIS, and SMITH, Circuit Judges.

JERRY E. SMITH, Circuit Judge:

The United States challenges the district court's holding that the proceeds of twelve key man insurance policies1 are not includable in the estate of Finis A. O'Daniel. The estate and its executors (collectively, the "Estate"),2 in turn, claim that the district court erred in holding that the estate was not entitled to estate tax deductions for deficiency interest that was later...

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