MEMORANDUM
CROAKE, District Judge.
This action brought by the plaintiff seeks a refund in Federal Estate Taxes in the sum of $12,963.39. The facts, as agreed upon by the parties, are not in dispute.
On June 13, 1925, prior to bringing an action for divorce in Massachusetts, Charles T. Lovering (hereinafter the "decedent") entered an agreement (hereinafter the "Original Agreement") with his wife Ellen Lyman Lovering (hereinafter his "wife").
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