TAXIS, J., January 16, 1980.
Noel Theodora Sferra, Richard Joseph LaMont, and Roland J. Christy, executors under the will of Theodore LaMont, petitioned the court for issuance of a citation to the Internal Revenue Service (I.R.S.) directing it to show cause why a claim or claims, if any, of I.R.S. should not be dismissed. In response thereto I.R.S. moved to dismiss the suit for lack of subject matter jurisdiction in this court.
I.R.S. claims that decedent...
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