FINDINGS OF FACT AND CONCLUSIONS OF LAW
MENTZ, District Judge.
The taxpayer, the Estate of Alice B. Smith, brought suit for refund from the government of $210,194.65. This amount represents a deficiency assessment and penalty paid by the taxpayer in relation to the filing of its estate tax return. The matter was tried before the Court on July 2, 1984. The parties were given an opportunity to file post trial briefs, and the matter was taken under submission...
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