ORDER
KERN, Chief Judge.
Before the Court are the Plaintiff's motion for partial summary judgment (# 37) and Defendants' cross motion for partial summary judgment (# 44).
BACKGROUND
The Government has sued the Estate of Birnie Davenport and individual Defendants Patricia L. Vestal, Gordon E. Davenport and Charles E. Botefuhr. The United States Tax Court has previously found the Estate liable for a federal gift tax deficiency...
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