MEMORANDUM
HUNGATE, District Judge.
Pursuant to the consent order entered February 15, 1983, this case was tried to the Court based on the parties' joint stipulation of facts and documentary exhibits, filed February 8, 1983, and the written memoranda of the parties regarding the legal issues remaining in dispute.
This action was filed to obtain a refund of certain federal estate taxes paid by plaintiff, Sue Fein, as personal representative of the...
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