Legal Opinion

First National Bank of Pennsylvania v. United States

District Court, W.D. Pennsylvania

Decided July 30, 1975No. Civ. A. 73-61 ERIEPublishedCited by 1 opinion

1Opinion of the Court

OPINION

WEBER, District Judge.

Plaintiff Executor seeks to recover Estate Tax paid upon a disallowed deduction for a debt.

Decedent H. L. Emmet, Sr., died testate July 15, 1968. Plaintiff was Executor of his estate. The gross estate amounted to $1,332,222.47. The distributive share of decedent’s son, H. L. Em-met, Jr. in the estate amounted to more than the debt in question.

At the time of decedent’s death his son, H. L. Emmet, Jr. owed the Bank, which is also Executor of the estate, $94,431.73 on a demand note signed October 4, 1967. On June 6, 1968 decedent had deposited personal securities as…

2Cases cited9 opinions

  1. Neuman v. Corn Exchange National Bank & Trust Co.Supreme Court of Pennsylvania · 1946
  2. Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1929
  3. Dickinson's EstateSupreme Court of Pennsylvania · 1892
  4. Donaldson's EstateSupreme Court of Pennsylvania · 1893
  5. In the Matter of Eton Furniture Company, Bankrupt. Morton S. Gorelick, TrusteeCourt of Appeals for the Third Circuit · 1961

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3Cited by1 opinion

  1. Suburban Nursing & Mobile Homes, Inc. v. ShawDistrict Court of Appeal of Florida · 1986

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