MEMORANDUM OPINION AND ORDER
REGAN, District Judge.
This is an action, tried to the Court, to recover federal estate taxes paid by plaintiff as transferee of the estate of Elmer L. Kellmann, Deceased. Plaintiff is the widow of Elmer, who died testate on April 27, 1963. The sole controverted issue is whether the property interests passing to the widow under Elmer's will are nondeductible terminable interests which do not qualify for the marital deduction...
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