MEMORANDUM AND ORDER
JAMES McGIRR KELLY, District Judge.
This is an action against the government filed by the executor of the estate of Frank W. Netsky ("decedent") asserting a claim for a refund of $1,233,739.89 in estate taxes, plus costs and interest. Jurisdiction is predicated on 28 U.S.C. § 1346(a)(1). The parties have filed cross motions for summary judgment based on the undisputed facts in the record. For the reasons stated in this Memorandum...
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