Manufacturers Hanover Trust Company, as of the Estate of Charlotte C. Wallace v. United States

GEORGE C. PRATT, Circuit Judge:

The question presented in this appeal by the United States from the summary judgment in Manufacturers Hanover Trust Co. v. United States, 576 F.Supp. 837 (S.D.N.Y.1983), Charles E. Stewart, Judge, is whether the Internal Revenue Service’s use of gender-based mortality tables to value reversionary interests of a decedent’s estate under 26 U.S.C. § 2037 violates the equal protection guaranteed by the due process clause of the fifth amendment. The IRS, following regulations in effect from 1970 to 1983, used gender-based mortality tables to calculate the estate tax…