HEALEY, District Judge.
This is an action by the executor of the estate of Henry F. Sears for the recovery of $174,392.01, and interest paid of $7,635.02, representing a portion of the Federal Estate Taxes paid upon the estate of Henry F. Sears.
The case was submitted on the pleadings, stipulation of facts, arguments and briefs of counsel.
The stipulation of facts filed by the parties, which is adopted as part of my findings of facts is as follows...
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