ORDER ON MOTION FOR SUMMARY JUDGMENT
ZOSS, United States Magistrate Judge.
I. INTRODUCTION
On August 25, 1997, the plaintiffs, Theron S. Bailey and George Byron Bailey ("the Baileys"), as co-executors of the estate of Ray V. Bailey, filed a complaint against the United States of America ("government"), seeking to recover federal estate taxes which they allege were illegally and erroneously assessed and collected from them. In particular...
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