CLANCY, District Judge.
Plaintiff's testator died on December 27, 1931. Payment of the estate taxes became due December 27, 1932. On December 22, 1932, in answer to a letter from the executor, the Commissioner wrote to him granting an extension of two months for the filing of the return. On December 24, 1932, the executor sent to the Collector a check for $20,000 and a letter enclosing it which stated that it was "to apply on account of the federal estate tax liability...
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