MEMORANDUM
MEREDITH, District Judge.
This matter is before the Court on final submission of a claim for refund of a deficiency assessment, statutory penalty and interest on this amount levied against plaintiffs in the amount of $359,412.11.
The entity from which the estate tax liability in issue principally stems is the Estate of Ethyle Boeving. The William Boeving Trust, a transferee of assets deemed includable in the "gross estate" of the Estate...
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