MEMORANDUM OPINION
KEADY, Chief Judge.
This action was instituted by Charles E. Waldrup, Executor of the Last Will and Testament of Marion T. Waldrup, Sr., deceased, against the United States of America, seeking the refund of federal estate taxes in the amount of $12,850.62, together with interest and attorney's fees. Plaintiff has moved for summary judgment on the basis of stipulated facts, exhibits and uncontradicted affidavits, which we hereby set forth...
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