OPINION AND ORDER
BATTIN, Chief Judge.
Presently pending before the Court are plaintiffs' and defendant's cross-motions for summary judgment. For the reasons stated below, plaintiffs' motion is denied and defendant's motion is granted.
FACTS AND CONTENTIONS
At issue is the deductibility of a $7,500.00 fee paid by the plaintiffs in 1976 to establish a family trust prepared by Estate Guardian Educational Trust (E.G.E. T.). Plaintiffs terminated...
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