WEINMAN, Chief Judge.
This is a tax refund action brought by plaintiff, estate of Harry A. Toulmin, Jr., against the defendant, United States of America, seeking a refund of $202,745.45 plus interest for estate tax allegedly wrongfully assessed and collected by the Internal Revenue Service. This amount arose from the disallowance of a charitable deduction for the present value of a testamentary trust remainder interest passing to Georgetown University Medical School...
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