MEMORANDUM
HERMAN, District Judge.
This action arises under the Internal Revenue Code of 1954 and involves a claim for refund pursuant to 26 U.S.C. § 7422. Jurisdiction to hear this claim is conferred by 28 U.S.C. § 1346(a)(1). The motions now under consideration are cross-motions for partial summary judgment.
The issue to be decided is whether Section 2055 of the Code requires that a charitable deduction be reduced by the maximum amount...
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