OPINION AND ORDER GRANTING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
PAUL D. BORMAN, District Judge.
I. INTRODUCTION
This is a federal tax case. Plaintiff, the Estate of Sarah M. Davenport ("the Estate"), seeks a $262,932 refund of federal estate taxes assessed and collected by Defendant, the United States, following the death of Sarah M. Davenport ("Decedent"). The government argues that the Court lacks jurisdiction over this case pursuant...
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