DAWKINS, Senior District Judge.
RULING ON MOTIONS
Presented for decision are cross motions for summary judgment. Herbert H. Land, Jr., and John Edgar Land claim that they wrongfully were assessed additional estate tax after closing their mother's succession. They paid the additional assessment under protest and now seek a refund from the United States, which opposes their claim. Our jurisdiction rests upon 28 U.S.C. § 1346(a)(1).
Plaintiffs...
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