MEMORANDUM OPINION
ARTHUR J. SCHWAB, District Judge.
Before the Court are the parties' cross-motions for summary judgment. The Estate of Antonio Palumbo and its Executor (hereinafter "Plaintiff") brought this action seeking a refund (plus accrued interest) of an alleged overpayment of Federal estate taxes. Plaintiff paid federal estate taxes on an amount — $11,721,141.00 — which was paid to a charitable trust created by Mr. Palumbo during his...
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