United States Court of Appeals for the Second Circuit, Docket No. 87-6046: United States of America, and James M. Serling, Estate Tax Attorney, Internal Revenue Service, Petitioners-Appellants, V. James M. White, as Attorney for and as the Executor of the Estate of Helen P. Smith, Deceased, Respondent-Appellee, on Appeal from a Judgment of the United States District Court for the Western District of New York, Amicus Curiae Brief Submitted by
