DAWKINS, Senior District Judge.
RULING ON CROSS MOTIONS
Plaintiffs, Herbert P. Reardon and John E. Reardon, claim that defendant, United States of America, through the Internal Revenue Service (I.R.S.), wrongfully made an estate tax deficiency assessment upon corporate stock which they inherited from their father, Herbert H. Reardon. Plaintiffs seek a refund for the additional assessment which they paid under protest. Our jurisdiction rests upon 28 U.S.C...
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