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CRESTAR BANK v. I.R.S.

No. Civ.A. 3:98cv321.

47 F.Supp.2d 670 (1999)

CRESTAR BANK and Diane Linen Powell, as Executors of the Estate of James A. Linen, IV, Plaintiffs, v. INTERNAL REVENUE SERVICE and United States of America, Defendants.

United States District Court, E.D. Virginia, Richmond Division.

April 26, 1999.

Attorney(s) appearing for the Case

Robert S. Parker, Richmond, VA, for plaintiffs.

Joan E. Evans, United States Attorney's Office, Richmond, VA, Stuart D. Gibson, United States Department of Justice, Ben Franklin Station, Washington, DC, for defendants.

MEMORANDUM OPINION

PAYNE, District Judge.

Plaintiffs, the Executors of the Estate of James A. Linen, IV ("the Estate"), instituted this action against the Internal Revenue Service ("IRS") seeking a federal income tax refund in the amount of $281,604 plus interest and costs by virtue of a claimed charitable deduction on a fiduciary income tax return which the IRS disallowed under the Internal Revenue Code ("I.R.C.") § 642(c), 26 U.S.C. § 642(c)...

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