Court of Appeals for the Second Circuit April 1, 1981, Nos. 341, 342, Dockets 80-6049, 80-6059 (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.