MEMORANDUM AND ORDER
DOUGLAS P. WOODLOCK, District Judge.
Plaintiff D. Charles Dickow, as the Executor of the Estate of Margaret W. Dickow, seeks to recover federal estate tax he claims has been erroneously assessed and collected by the Internal Revenue Service ("IRS") for the tax year ending on January 15, 2003. The IRS and the Executor have moved respectively for summary judgment and partial summary judgment over the issue of the timeliness of the...
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