KASHIWA, Judge:
This case is before the court on cross motions for summary judgment. After careful consideration of the parties' submissions, and after oral argument, we grant plaintiff's motion in part and deny it in part.
The plaintiff, the Estate of Dorothy B. Plumb, filed a federal estate tax return on July 17, 1978. As of that date, plaintiff had fully paid its Massachusetts state death taxes of $3,384,910.50. In computing the state death tax credit provided...
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