MEMORANDUM OPINION
NANGLE, District Judge.
This matter comes before the Court upon cross-motions for summary judgment filed by the plaintiffs and the defendant. The plaintiffs, trustees of the Parsons Blewett Memorial Fund, seek a refund of income taxes paid by the Parsons Blewett Memorial Fund to the United States for the Fund's taxable years ended June 30, 1962, through June 30, 1968, in the aggregate sum of $1,017,779.53. Jurisdiction is predicated upon...
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