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MANUFACTURERS HANOVER TRUST CO. v. UNITED STATES

No. 82 Civ. 724 (CES).

576 F.Supp. 837 (1983)

MANUFACTURERS HANOVER TRUST COMPANY, as Executor of the Estate of Charlotte C. Wallace, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S.D. New York.

October 17, 1983.

Attorney(s) appearing for the Case

Kelley, Drye & Warren by Robert E. Crotty, New York City, for plaintiff.

Rudolph W. Giuliani, U.S. Atty. by David M. Jones, Asst. U.S. Atty., New York City, for defendant.

MEMORANDUM DECISION

STEWART, District Judge:

This action is brought by Manufacturers Hanover Trust Company, as executor of the estate of Charlotte C. Wallace ("Estate"). Plaintiff challenges the Commissioner of Internal Revenue's ("Commissioner") use of gender-based mortality tables in calculating the present value of the reversionary interest in the trust of the decedent. This valuation determines whether the...

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