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U.S. v. TAYLOR

Nos. 01-2874, 01-3872.

338 F.3d 947 (2003)

UNITED STATES of America, Appellee, v. Francis TAYLOR, Defendant, Mary E. Taylor, Appellant.

United States Court of Appeals, Eighth Circuit.

Filed: July 31, 2003.

Attorney(s) appearing for the Case

Peter D. Gray, argued, Minneapolis, MN, for appellant.

Marion E.M. Erickson, Washington, DC (Eileen J. O'Connor, Teresa E. McLaughlin, on the brief), for appellee.

Before LOKEN, BYE, and RILEY, Circuit Judges.

RILEY, Circuit Judge.

This case arises out of an April 1996 Northwest Airlines (Northwest) interpleader of the United States and Mary Taylor (Mary) to determine whether the Internal Revenue Service (IRS) or Mary has priority and is entitled to the benefits of three Northwest sponsored employee benefits plans. On cross motions for summary judgment, the district court ruled generally for the IRS and against Mary, finding Mary's right to the plans under a

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