OPINION
ZIEGLER, District Judge.
I. History of Case
This is a civil action to recover penalties and interest assessed and paid for the late filing of a federal estate tax return. Jurisdiction is conferred by 28 U.S.C. § 1346(a)(1) and 26 U.S.C. § 7422. Presently before the court are cross motions for summary judgment.
The salient facts in this matter are not in dispute. Plaintiff, Scott W. Lewis, is the administrator of...
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