SCHATZ, District Judge.
Plaintiff, Vantine A. James, Executor of the Estate of Marie O. Neal, brought this action for refund of estate taxes paid following an I.R.S. deficiency assessment on one-third interests in two trusts which Mrs. Neal had helped to establish for her grand-children. Each party filed a motion for summary judgment (Filing Nos. 10 and 17), and following a hearing on the motions...
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