MEMORANDUM OPINION
REGAN, District Judge.
This is an action for refund of federal estate taxes and interest. We have jurisdiction under Section 1346(a) (1), 28 U.S.C. The sole controverted issue is the correctness vel non of the Commissioner's calculation of the marital deduction. The relevant facts have been stipulated and are not in dispute.
Decedent died testate, survived by his widow and one son. His will directs...
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