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ESTATE OF BURCHELL v. U.S.

No. 96 CIV. 6757(JSR).

146 F.Supp.2d 382 (2001)

ESTATE OF Llewellyn BURCHELL, the Chase Manhattan Bank, formerly Chemical Bank, Executor, Plaintiff, v. UNITED STATES of America, Defendant.

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

May 29, 2001.

Attorney(s) appearing for the Case

Michael Frankel, Carter, Ledyard & Milburn, New York City, for Plaintiff.

Maya Wiley, Kathy Marks, Assistant United States Attorney, United States Attorney's Office, New York City, for Defendant.

ORDER

RAKOFF, District Judge.

On this motion for summary judgment, the pertinent facts, either undisputed or, where disputed, taken most favorably to the plaintiff, are as follows. At her death on January 1, 1991, Llewellyn Burchell ("Llewellyn") left a testamentary charitable remainder unitrust, granting a life tenancy to her 67-year-old stepson Samuel Burchell III ("Samuel") and the remainder to the Columbia University College of Physicians and...

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