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RUPERT EX REL. ESTATE OF KNEPP v. U.S.

Civ.A. No. 1:CV-03-0421.

358 F.Supp.2d 421 (2004)

Dorothy L. RUPERT, Executor of the Estate of Rosie E. KNEPP; and Dorothy L. Rupert and Omega Bank, N.A., Co-Trustees under Agreements of Trust of Rosie E. Knepp dated September 2, 1994 and July 13, 1994; Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, M.D. Pennsylvania.

October 22, 2004.

Attorney(s) appearing for the Case

Elizabeth J. Goldstein, Elyse E. Rogers, Keefer, Wood, Allen & Rahal, LLP, Camp Hill, PA, for plaintiffs.

Dara B. Oliphant, Trial Attorney, Tax Division, U.S. Department of Justice, Washington, DC, Lorna N. Graham, Scranton, PA, for defendant.

MEMORANDUM

CALDWELL, District Judge.

I. Introduction.

In 1991, at the age of seventy-nine, Rosie E. Knepp won the Pennsylvania Lottery and began receiving payments of about $630,000, to be paid annually over a period of twenty-one years. She died in August of 1997, with the lottery payments dwarfing all other assets in her estate.

The plaintiffs are Dorothy L. Rupert, Knepp's daughter and the executor of her estate, and Omega...

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