FINDINGS, CONCLUSIONS, OPINION AND ORDER
PARKER, District Judge.
Plaintiff The Howard Bank, as administrator of the Estate of Thomas C. Sawyer, filed suit seeking a refund of certain estate taxes paid to the United States. The United States Internal Revenue Service (IRS) concedes that it overassessed the value of the Sawyer Estate, but denied a refund on the sole ground that plaintiff failed to file suit within the statutory limitations period set forth...
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