MEMORANDUM OPINION AND ORDER
ATKINS, Senior District Judge.
THIS CAUSE came before the court for non-jury trial on October 27 and 28, 1992. Sondra Rubenstein (Rubenstein) and Barry Tobias (Tobias) (collectively referred to as plaintiffs), brought this action for the refund of estate tax, pursuant to Internal Revenue Code (I.R.C.) §§ 6532(a)(1) and 7422(a).
FINDINGS OF FACT
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