MEMORANDUM OF DECISION
THEIS, District Judge.
This action arises under the Internal Revenue laws of the United States, and is here now on cross-motions for summary judgment. The plaintiff's complaint prays for recovery of estate taxes and interest thereon assessed against the Estate of Carl H. Schmidt pursuant to 26 U.S.C.A. § 2001, as amended. The Court finds, as a preliminary matter, that it has jurisdiction of the subject matter and the parties to...
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