OPINION
NIMS, Judge:
This matter is before the Court on the parties' cross-motions for partial summary judgment, filed pursuant to Rule 121. The parties seek a summary adjudication regarding the same matter; i.e., the proper application of section 2702 to four grantor retained annuity trusts (GRAT's). There is no genuine issue of material fact to preclude a decision on such matter. We therefore proceed to decide the legal issues that the parties'...
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