Estate of Charles J. Wyly, Sr., Flora E. Wyly, Independent (Charles J. Wyly, Jr. And Samuel Evans Wyly Substituted in the Place and Stead of Flora E. Wyly, Independent Deceased) v. Commissioner of Internal Revenue, Estate of Winston C. Castleberry, Deceased, Republic National Bank of Dallas, Independent Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant. Russell M. Frankel, Donald E. Woodard and Southern National Bank of Houston, as Independent Co-Executors of the Estate of Jules R. Frankel, Deceased v. United States

610 F.2d 1282

80-1 USTC P 13,332

ESTATE of Charles J. WYLY, Sr., Flora E. Wyly, Independent

Executrix (Charles J. Wyly, Jr. and Samuel Evans Wyly

substituted in the place and stead of Flora E. Wyly,

Independent Executrix, Deceased), Petitioner-Appellant,

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

ESTATE of Winston C. CASTLEBERRY, Deceased, Republic

National Bank of Dallas, Independent Executor,

Petitioner-Appellant Cross-Appellee,

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee

Cross-Appellant.

Russell M. FRANKEL, Donald E. Woodard and Southern National

Bank of Houston, as…