[Download] "United States v. Manny" by Second Circuit United States Court Of Appeals ~ Book PDF Kindle ePub Free
eBook details
- Title: United States v. Manny
- Author : Second Circuit United States Court Of Appeals
- Release Date : January 01, 1981
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 63 KB
Description
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 bonds had been accepted, upon further investigation, the Internal Revenue Service (""IRS"") assessed a deficiency in each estate and offered to return the bonds. At issue is whether the flower bonds, purchased in bearer form from third parties, paid for and delivered, but acquired while Manny and Timolat were comatose, through the agency of persons holding powers of attorney to trade in securities, are eligible for redemption at par in payment of federal estate taxes. The district court, 463 F. Supp. 444, held in each case that the bonds were eligible. We affirm.