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UNITED STATES v. WELLS FARGO BANK

No. 86-1521.

485 U.S. 351 (1988)

108 S.Ct. 1179

99 L.Ed.2d 368

UNITED STATES v. WELLS FARGO BANK ET AL.

Supreme Court of United States.

Decided March 23, 1988

Attorney(s) appearing for the Case

Deputy Solicitor General Wallace argued the cause for the United States. On the briefs were Solicitor General Fried, Acting Assistant Attorney General Durney, Deputy Solicitor General Lauber, Alan I. Horowitz, Michael L. Paup, Ernest J. Brown, and David I. Pincus.

Robert H. Rotstein argued the cause for appellees. With him on the brief for appellees Wells Fargo Bank et al. were William J. Bird and Katherine T. Pratt. Mark G. Ancel and Erwin N. Griswold filed a brief for appellees Rosenberg and Rosen.*

John A. Wallace filed a brief for the American College of Probate Counsel as amicus curiae.

JUSTICE BRENNAN delivered the opinion of the Court.

This case, which consists of two actions consolidated below, Wells Fargo Bank v. United States and Rosenberg v. United States, 86-2 USTC ¶ 13,703 (CD Cal. 1986), presents two issues: first, whether certain state and local public housing agency obligations (Project Notes or Notes) were exempt from federal estate taxation prior to June 19, 1984, and second, if so, whether § 641...

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