OPINION
DAVID S. PORTER, Senior District Judge.
This is an action for the refund of federal income taxes and interest paid by an estate in 1976 in the amount of $20,740.65 plus statutory interest. Plaintiff has pursued her administrative remedy without success. The parties have agreed to submit this case to the Court for decision on stipulation of facts (docs. 6, 8) and trial memoranda (docs. 7, 9).
The legal question presented is whether plaintiff...
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