LITTLETON, Judge.
The overpayment which the plaintiffs seek to recover in this case constitutes a part of the total of the estate tax determined by the Commissioner of Internal Revenue and paid on the net estate of the decedent. An estate tax return was duly filed and the tax assessed thereon was paid. The Commissioner subsequently audited the return and determined, assessed, and demanded deficiencies of $115,302.77 and $2,700.22, which were paid on August 19, 1925...
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