Memorandum of Decision
RAY W. ZOBEL, District Judge.
I. OVERVIEW
Plaintiff Craig E. Breakiron ("Craig Breakiron" or "Craig") brings this action to rescind two disclaimers of undivided interests in real property located in Nantucket County, Massachusetts, in order to avoid triggering the imposition of a federal gift tax. Craig initially filed suit in state court; the United States removed to this court, opposed rescission, and filed a counterclaim...
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