MEMORANDUM
GUNN, District Judge.
This matter is before the Court on cross-motions for summary judgment.
Plaintiffs Centerre Trust Co. of St. Louis and Edward C. Simmons III, co-executors of the Estate of Edward C. Simmons II, bring this action against defendant United States of America for a refund of federal estate taxes which they allege the Commissioner of Internal Revenue ("Commissioner") erroneously assessed against and collected from the Estate...
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