MEMORANDUM OPINION AND ORDER
HEARTFIELD, District Judge.
This is a civil action for the recovery of federal gift taxes and related interest. Plaintiff Arthur Temple ("Temple"), individually and as independent executor of the estate of his wife, Mrs Charlotte Dean ("Lottie") Temple, alleges that the federal government, through the Internal Revenue Service ("IRS"), erroneously and wrongfully assessed and collected gift taxes from 6. Temple and from...
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