OPINION
NATURE OF PROCEEDINGS
EAST, District Judge.
The Washington Trust Bank, as Trustee above (Trust Bank), seeks to recover on behalf of the Endowment Care Fund of Greenwood Memorial Terrace Company (Greenwood Trust) a refund of federal income taxes paid to the United States of America (Government) for the calendar years of 1963 and 1964 in the amounts of $21,819.95 and $5,162.65, respectively, together with interest thereon as allowed by law...
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