UNITED STATES v. KAHN

Docket No. 19-3920. August Term, 2020.

5 F.4th 167 (2021)

UNITED STATES of America, Plaintiff-Appellee, v. Jeffrey KAHN, as co-executor of the estate of Harold Kahn, and Joel Kahn, as co-executor of the estate of Harold Kahn, Defendants-Appellants.

United States Court of Appeals, Second Circuit.

Decided: July 13, 2021.


Attorney(s) appearing for the Case

JULIE CIAMPORCERO AVETTA , Tax Division, Department of Justice, Washington, D.C. ( Richard E. Zuckerman , Principal Deputy Assistant Attorney General, Joshua Wu , Deputy Assistant Attorney General, Francesa Ugolini , Geoffrey J. Klimas , Attorneys, Tax Division, Department of Justice, Washington, D.C.; Seth D. DuCharme , Acting United States Attorney for the Eastern District of New York, New York, New York, on the brief), for Plaintiff-Appellee.

JAMES N. MASTRACCHIO , Washington, D.C. ( Daniel G. Strickland , Eversheds Sutherland (US), Washington, D.C., on the brief), for Defendants-Appellants.

Judge Menashi dissents in a separate opinion.


Defendants Jeffrey and Joel Kahn, as co-executors of the estate of Harold Kahn ("Kahn"), appeal from a judgment of the United States District Court for the Eastern District of New York, Kiyo A. Matsumoto, Judge, in favor of the United States against defendants as co-executors of the Kahn estate (the "Estate") in the...

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