MEMORANDUM OPINION
BRYAN, District Judge.
This case is before the court on the plaintiff's motion for attorney's fees made pursuant to 26 U.S.C. § 7430.
This action for a refund of estate taxes was filed, pursuant to 28 U.S.C. § 1346(a), on September 12, 1983. The United States filed its answer denying liability on November 17, 1983. By agreement of counsel at the February 16, 1984 pretrial conference...
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