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FIRST ALABAMA BANK, N.A. v. U.S.

Civ. A. Nos. 89-0141-B, 89-0142-B.

768 F.Supp. 1522 (1991)

FIRST ALABAMA BANK, N.A., etc., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, S.D. Alabama, S.D.

On Motion for New Trial July 26, 1991.

Attorney(s) appearing for the Case

W. Dewitt Reams, Richard L. Reid, Mobile, Ala., for plaintiffs.

J.B. Sessions, U.S. Atty., Mobile, Ala., Carol Ide, Tax Div. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION AND ORDER

BUTLER, District Judge.

This matter came before the Court for an evidentiary hearing on the defendant's motion to dismiss for lack of subject matter jurisdiction. These consolidated actions involve claims for recovery of federal estate taxes paid by the Estate of Bruce Cogle and for the recovery of federal estate and gift taxes paid by the Estate of Rosa Cogle. The government contends that because these actions were not timely...

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