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MUNICIPAL TRUST AND SAV. BANK v. U.S.

No. 96-3055.

114 F.3d 99 (1997)

MUNICIPAL TRUST AND SAVINGS BANK, Plaintiff-Appellee, v. UNITED STATES of America, Intervenor-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided May 8, 1997.

Rehearing Denied June 27, 1997.

Attorney(s) appearing for the Case

Marc A. Primack, John J. Blasi (argued), James W. McConkey, Rooks, Pitts & Poust, Chicago, IL, Thomas W. Murphy, Richard C. Perna, Johnson & Bell, Chicago, IL, Jerome C. Shapiro, Kankakee, IL, for Municipal Trust & Savings Bank.

Valerie K. Smith, Sacks, Albrecht, Copeland, Herzog & Sacks, Kankakee, IL, for Robert P. Geekie, Jr., Michelle Geekie.

Richard N. Cox, Office of the United States Attorney, Urbana Division, Urbana, IL, Regina S. Moriarty (argued), Bruce Ellisen, Department of Justice, Tax Division, Appellate Section, Barbara E. Seaman, Department of Justice, Tax Division, Washington, DC, for United States of America.

Before WOOD, Jr., COFFEY, and EASTERBROOK, Circuit Judges.

EASTERBROOK, Circuit Judge.

Richard and Leah Unz died in 1977; their estate owes more than $800,000 in taxes. (For simplicity we refer to the "Unz estate" in the singular; a distinction between Leah's estate and Richard's becomes necessary later.) Richardson Bradshaw (Brad) Unz, their son and heir, managed to have some of the estate's property distributed to him without satisfying the estate's tax obligation. He resold that property. Now the United States wants to...

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