OPINION
KEVIN THOMAS DUFFY, District Judge:
This action arises as a result of a dispute between the United States government and the co-executors of the estate of Walter Roy Manny. The government is seeking a judgment for unpaid estate taxes and interest of $1,023,486.51 plus statutory additions. Defendants contend that the bulk of this amount has been paid by virtue of the tender of 3½% United States Treasury Bonds with a face amount of $775,000. The...
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