MEMORANDUM OPINION
GLEN M. WILLIAMS, District Judge.
The plaintiffs have filed this action to recover taxes and penalties paid to the Internal Revenue Service ("IRS" or "the Government"). The plaintiffs allege the estate tax deficiency assessment was erroneous on four different items and also protest the imposition of the penalty for the late filing of the Estate Tax Return. Jurisdiction attaches pursuant to 28 U.S.C. § 1346.
The plaintiffs...
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