ROCHE, District Judge.
Plaintiffs seek, by this action, to recover the sum of $195,342.63 which they paid, under protest, on December 8, 1942, as a deficiency Federal estate tax assessed by the Commissioner of Internal Revenue on the estate of Edwin P. Gamble, deceased. Plaintiffs had previously filed a return for said decedent's estate but had not included therein the assets of an irrevocable trust created by Mr. Gamble on February 28, 1927. The Commissioner deemed...
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