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FLORIDA NATIONAL BANK AT ST. PETERSBURG v. UNITED STATES

Civ. A. No. 68-344 Civ.T.

310 F.Supp. 1321 (1969)

FLORIDA NATIONAL BANK AT ST. PETERSBURG, as Executor of the Estate of Stella Rae Connelly, Deceased, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, M. D. Florida, Tampa Division.

September 19, 1969.

Attorney(s) appearing for the Case

Michel G. Emmanuel, Norman H. Lipoff, of Carlton, Fields, Ward, Emmanuel, Smith & Cutler, Tampa, Fla., Thomas M. Harris, St. Petersburg, Fla., for plaintiff.

Thomas G. Wilson, Asst. U. S. Atty., Eugene P. Kopp, Refund Trial Section #2, Tax Division, Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM OPINION

KRENTZMAN, District Judge.

Florida National Bank at St. Petersburg, as Executor of the Estate of Stella Rae Connelly, Deceased, sues for a refund of federal estate taxes claimed to have been excessively and erroneously collected by the Internal Revenue Service. The only issue is the District Director's disallowance of charitable deductions from the decedent's gross estate in respect to a trust which provides for a life estate in income...

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