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MILDRED COTLER TRUST v. U.S.

No. 98-6095.

184 F.3d 168 (1999)

The MILDRED COTLER TRUST, John W. Hughes, Shirley Mellon, Trustees, The Justine Chelsea Brandy Trust, Trustees, and Estate of Mildred Cotler, Executrix, and Shirley Mellon Trust, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided July 9, 1999.

Attorney(s) appearing for the Case

John W. Hughes, New York, NY, for Appellants.

David English Carmack, Tax Division, Department of Justice, Washington, DC. (With him on the brief were Regina S. Moriarty, and Loretta C. Argrett, Assistant Attorney General. Zachary W. Carter, United States Attorney, was of counsel), for Appellee.

Before: FEINBERG, LEVAL, and MICHEL, Circuit Judges.

MICHEL, Circuit Judge.

Plaintiffs-Appellants, The Mildred Cotler Trust, et al., appeal from the judgment in favor of the United States entered on March 17, 1998 by the United States District Court for the Eastern District of New York (District Judge John Gleeson), following a bench trial. See The Mildred Cotler Trust, et al. v. United States, 2 F.Supp.2d 264 (E.D.N.Y.1998). The Mildred Cotler Trust, et al., filed the...

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