OPINION
SUE E. MYERSCOUGH, District Judge.
This cause is before the Court on the parties' cross-motions for summary judgment. See Plaintiff's Motion for Summary Judgment (d/e 10); Defendant's Motion for Summary Judgment (d/e 11). The sole issue is whether Treasury Regulation 20.2032A-8(a)(2) (26 C.F.R. § 20.2032A-8(a)(2)) is a valid regulation. For the reasons that follow, this Court finds that the regulation is invalid. Because additional...
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