OPINION
ROBERT M. McRAE, Jr., District Judge.
In this case the plaintiff sues for a partial refund of estate tax based upon the disallowance by the Commissioner of Internal Revenue of a deduction taken by the plaintiff in the amount of the value of a charitable remainder interest in a trust, which remainder interest was subject to a life interest with a power of encroachment in favor of an individual beneficiary. The matter was presented to the Court on...
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