NAUMAN S. SCOTT, Chief Judge.
We have jurisdiction under 28 U.S.C. § 1346(a)(1) of these three consolidated cases for recovery of Internal Revenue taxes.
Two basic factual situations gave rise to the issues in these three consolidated tax refund cases. The first situation occurred in 1967 and relates to issues in all three cases.
In May of 1967 Horace B. Rickey, Sr. died, naming as universal legatees his three surviving children, Horace B. Rickey...
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