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CHRISTIERNIN v. MANNING

Civ. A. No. 258-50.

138 F.Supp. 923 (1956)

Regina Scott-Hall CHRISTIERNIN and the Chase National Bank of the City of New York, Executors of the Estate of Charles L. Christiernin, Plaintiffs, v. John E. MANNING, Collector of Internal Revenue, Defendant.

United States District Court D. New Jersey.

March 2, 1956.

Attorney(s) appearing for the Case

Osborne, Cornish & Scheck, by Abram H. Cornish, Newark, N. J., for plaintiffs.

Raymond Del Tufo, Jr., U. S. Atty., by George J. Rossi, Asst. U. S. Atty., Newark, N. J., of counsel. Walter B. Langley, Special Asst. to the Atty. Gen., for defendant.

HARTSHORNE, District Judge.

Plaintiffs bring this action to recover alleged overpayments of Federal estate taxes (former 26 U.S.C. § 810; 28 U.S.C. § 41(5)1). The issue hinges upon the proper valuation for estate tax purposes of that part of a joint survivorship annuity contract which is included in the estate of the first life as transmitted on his death.

The annuity contract...

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