LEIBELL, District Judge.
This is an action by the Administrator c. t. a. of the estate of John S. Adriance against the Collector of Internal Revenue for the Third District of New York to recover the sum of $49,467.20, or such lesser sum as he may be lawfully entitled to, with interest from March 3rd, 1936. It is alleged that the said sum was illegally and wrongfully exacted from the plaintiff by the defendant as a tax upon the estate of John S. Adriance. The defendant...
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