MEMORANDUM DECISION ON DEFENDANT'S MOTIONS TO DISMISS AND FOR PARTIAL SUMMARY JUDGMENT1
DAVID M. COHEN, United States Magistrate Judge.
In this estate-tax dispute, the United States of America (the "United States") moves pursuant to Fed.R.Civ.P. 12(b)(1) to dismiss Count II of the three-count complaint filed by John A. Davies as trustee of the Jack L. Gimbel Revocable Trust B (the "Trust"). United States' Motion...
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