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GILBERTON CONTRACTING COMPANY v. HOOK

Civ. A. Nos. 25474, 26079, 27696.

267 F.Supp. 393 (1967)

GILBERTON CONTRACTING COMPANY, Inc. v. Kenneth O. HOOK, District Director of Internal Revenue. UNITED STATES of America v. The RHOADS COMPANY, Inc. UNITED STATES of America v. GILBERTON CONTRACTING COMPANY, Inc., Rhoads Company, Inc. and Park Trent Coal Company, Inc.

United States District Court E. D. Pennsylvania.

April 24, 1967.

Attorney(s) appearing for the Case

LaBrum & Doak, Lewis Weinstock, Joseph G. Manta, Philadelphia, Pa., for Gilberton Contracting Co.

Drew J. T. O'Keefe, U. S. Atty., Sullivan Cistone, Asst. U. S. Atty., Philadelphia, Pa, David H. Hopkins, Jr., Trial Atty., Tax Div., Dept. of Justice, Washington, D. C., for United States.

Israel T. Klapper, George I. Puhak, Joseph T. Ustynoski, Hazleton, Pa., for Park Trent Coal Co., Inc.

OPINION

KRAFT, District Judge.

In prior proceedings in these actions1, we determined that Park Trent and Gilberton were co-owners of a large silt bank located in Schuylkill County, Pennsylvania. We concluded, too, that the tax liens of the United States were valid against the portion of the silt owned by Park Trent.

An adjudication was entered accordingly, but we reserved for later trial and decision, the following unresolved...

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