OPINION AND ORDER
JOHN W. LORD, Jr., District Judge.
This is an action for a refund of federal estate taxes, brought by the executors and successor trustees of the estate of Samuel Rudin. Plaintiffs' Motion for Summary Judgment is presently before the Court.
The case has been submitted to the Court upon a lengthy stipulation of facts. A brief summary of these facts, as stipulated by the parties, is as follows:
Samuel Rudin created an inter...
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