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PURNELL v. UNITED STATES

Civ. No. 69-246.

332 F.Supp. 65 (1971)

Verner S. PURNELL, Executor of the Estate of Anna S. PURNELL, Deceased, v. UNITED STATES of America.

United States District Court, W. D. Pennsylvania.

September 23, 1971.

Attorney(s) appearing for the Case

Dougherty, Larrimer, Lee & Hickton, Pittsburgh, Pa., for plaintiff.

Richard L. Thornburgh, U. S. Atty., Pittsburgh, Pa., for defendant.

OPINION and ORDER

KNOX, District Judge.

This suit for refund of federal estate taxes involves one of the more abstruse and obscure branches of the Pennsylvania law of decedent's estates. The rule formerly was that where under a will, personal property was awarded directly to a life tenant for life with remainder over, the life tenant was treated as a debtor to the remainder man in the amount of the personal property received by the life tenant. The relationship...

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