NICHOLS, Judge.
In this tax case, both plaintiff and defendant move for summary judgment. We grant defendant's motion.
Plaintiff is the estate of Azalea Smith Downs, whose suit to recover a refund of estate taxes allegedly overpaid requires us to consider the effect of the Powers of Appointment Act of 1951, Pub.L.No. 58, 65 Stat. 91 (1951) (now codified in 26 U.S.C. § 2041), (hereinafter 1951 Act) upon a power of appointment created while the prior law...
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