MEMORANDUM OPINION AND ORDER
PLUNKETT, District Judge.
Plaintiffs, Daniel F. McCarthy ("McCarthy") and First National Bank & Trust Company of Evanston, trustees of the estate of Melanie B. McCarthy ("decedent"), bring this action against the United States of America to recover $8,349 which plaintiffs deposited with the Internal Revenue Service under protest after a deficiency was assessed against the estate in that amount. Presently before the court...
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