Court of Appeals for the Ninth Circuit September 8, 1989, 88-6069 (Trust Services of America, Inc. Toni Brotman Wald v. United States)

TROTT, Circuit Judge:

The United States appeals the district court’s judgment that the United States is not entitled to any setoffs against the es

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tate tax refund due Trust Services of America, Inc. and Toni Brotman Wald (collectively “Trust Services”) in their capacity as cotrustees of the trust established by Alix Brotman Hodosh’s will.