DENNEY, District Judge.
This matter comes before the Court on cross-motions of the parties for partial summary judgment on the following stipulated facts and issues of law.
The decedent, Martha H. Hitchcock, died testate on December 15, 1962. Plaintiffs, as co-executors of the estate, timely filed a federal estate tax return with respect to decedent on March 16, 1964, and paid the estate tax shown to be due on the return in the amount of $9,469,302.00. On...
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