OPINION AND ORDER
POTTER, District Judge:
This matter is before the Court on cross motions for summary judgment filed by the parties. Plaintiff brought this action for an estate tax refund of $4,073.25 plus interest as provided by law for an estate tax return filed November 15, 1976. The estate involved is that of Challace Manley who died in February of 1976. Mr. Manley and his wife LuLu, who died in 1969, owned a farm scheduled as Parcel A in Mr. Manley...
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