FINDINGS OF FACT, OPINION AND ORDER
BILLINGS, Senior District Judge.
Plaintiff Elbert Crosby, Administrator of the Estate of Goodwin E. Crosby ("the Estate"), brings this suit against Defendant United States of America, to recover the $10,000 which the Estate submitted to the Internal Revenue Service ("IRS") when the Estate requested an extension of time to file a 1988 fiduciary tax return. The IRS refuses to refund the $10,000, alleging that the...
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