SOMERVILLE, Judge.
This litigation arises from polemical positions taken by individual residuary legatees (who were also recipients of non-probate property) and charitable residuary legatees as to where the final burden of the federal estate tax generated by decedent's estate (probate and non-probate) should rest.
There are two issues involved on appeal: FIRST, should the charitable residuary legatees be completely exonerated from the impact of the federal...
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