MEMORANDUM OPINION
WILLIAMS, District Judge.
I
Presently before the Court are cross-motions for summary judgment. In ruling on the motions, the Court has considered the briefs of the parties, the arguments of counsel at a hearing in open court, and the entire record.
II
Allan and Mary Rozansky (hereinafter sometimes "the Rozanskys", and "the settlors") established a trust for...
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