Estate of Harvey v. United States

OPINION

CHARLES SCHWARTZ, Jr., District Judge.

This matter was submitted to the Court on a stipulation of facts. The Court heard oral argument on the briefs on January 27, 1988. Having considered the record, the stipulation of facts, the arguments of counsel, and the applicable law, the Court rules as follows. To the extent any of the fol lowing findings of fact constitute conclusions of law, they are adopted as conclusions of law; to the extent any of the following conclusions of law constitute findings of fact, they are adopted as findings of fact.

This is a tax refund case. The parties…