CHRISTIE, District Judge:
Plaintiffs bring this action as executors of the estate of William McClellan Ritter, II, to recover an alleged overpayment of estate taxes for which claim for refund has been duly made and disallowed by the Commissioner of Internal Revenue. At issue in this proceeding are questions concerning whether or not the estate of certain trusts established by William McClellan Ritter, II, prior to his death should be included in his gross estate for...
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