First National Bank in Dallas, of the Estate of George Pattullo, Deceased v. The United States. Lucile W. Pattullo v. The United States

OPINION

LARAMORE, Judge.

In these suits, the First National Bank in Dallas, as executor of the estate of George Pattullo, and Lucile W. Pattullo (his widow), seek recovery of Federal excise taxes and interest paid by the Pat-tullos, individually, with respect to their purchases of certain stocks of Canadian corporations in late 1963 and early 1964. The dispositive issue involves the constitutionality of the Interest Equalization Tax Act of 1964 1 as applied to the transactions here involved. The facts are stipulated and will be summarized here only to the extent necessary to explain the basis…