OPINION
LECHNER, District Judge.
This is an action brought by the Estate of Esther D. Reddert (the "Estate") against the United States of America (the "Government") seeking recovery of Federal estate tax, interest and penalties. A complaint (the "Complaint") was filed on 14 February 1995. Jurisdiction is alleged pursuant to 28 U.S.C. § 1346(a)(1). Currently before the court is a motion for summary judgment filed by the
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