MEMORANDUM OPINION
ELLIS, District Judge.
Introduction
In this estate tax refund suit, the central issue is whether the Internal Revenue Service (IRS) properly disallowed a Section 2013 credit in connection with the tax return for the estate of Jean Marston Glendening. See 26 U.S.C. § 2013. Plaintiffs are Mrs. Glendening's sole beneficiaries. They contend the IRS erred in denying the credit. Indeed, they claim the refund should...
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