THOMAS, District Judge.
This action is for refund of a payment of an additional assessment of estate tax in the amount of $83,355.92 with interest from the date of payment, September 19, 1936. The assessment was made on the ground that a certain portion of a trust created by the decedent was intended to take effect in possession or enjoyment at or after his death. A claim for refund was disallowed on this ground and on the additional ground, put forward for the first...
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