United States v. Manny

BRIEANT, District Judge:

In these cases, consolidated for appeal, the United States sued in the district court to reduce to judgment and collect unpaid federal estate taxes assessed against the respective estates of Walter Roy Manny, deceased, and James G. Timolat, Jr., deceased. The estate representatives had tendered certain U.S. Treasury bonds, known popularly as “flower bonds,” sold under provisions which allow their use at par for the payment of estate taxes.1 Although the *165bonds had been accepted, upon further investigation, the Internal Revenue Service (“IRS”) assessed a deficiency in…