MEMORANDUM DECISION
MIDDLEBROOKS, District Judge.
This action is of a civil nature to compel the refund of estate taxes paid to the Internal Revenue Service by the plaintiff and arises under Title 28, United States Code, Section 1346 and under Section 7422 of the Internal Revenue Code of 1954, as amended. The plaintiff in this action seeks recovery of federal estate taxes alleged to have been erroneously and illegally assessed against, imposed upon and collected...
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