ORDER
McAULIFFE, District Judge.
In this suit, the Estate of Dorothy Hyde seeks a refund of estate taxes it claims to have overpaid as a result of its having mistakenly included in the decedent's gross taxable estate the value of certain trust assets over which Hyde had a power of appointment. The Internal Revenue Service ("IRS") refused the refund claim on grounds that the decedent held a general power of appointment, effectively making the assets...
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