OPINION
CAFFREY, District Judge.
This is a civil action brought for the refund of federal estate taxes of $84,953.82 and interest in the sum of $12,854.39. The complaint also seeks a ruling determining the amount of attorneys' fees properly allowable as a deduction from the estate tax under the provisions of the estate tax regulation 20.2053(c) (2), 26 C.F.R. 20.2053(c) (2). All of the factual allegations of the complaint are admitted in defendant's answer...
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