OPINION
RICHARD MILLS, District Judge:
Taxpayer suit for tax refund.
Civil action under 28 U.S.C. § 1346(a)(1) for recovery of a denied refund of estate taxes.
This cause is before the Court on competing motions for summary judgment.
Summary judgment for the government.
I. Issue
The basic issue before us is whether the trust funds that the decedent set up for her grand nieces and nephews are subject to a "substantial...
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