MEMORANDUM OPINION
VARNER, District Judge.
This is a civil action seeking the recovery of estate taxes assessed by the Internal Revenue in the amount of $23,491.77. Plaintiffs are the duly appointed executors of the estate of J. A. Grant, Jr., deceased, and are residents of the Middle District of Alabama. The existence of all necessary jurisdictional facts is admitted by the parties.
By agreement by and between the parties this case is submitted...
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