DAVIS, District Judge.
1. Plaintiff is the duly qualified and acting executor of the estate of Otto Schwab, who died February 23, 1943.
2. The defendant is the Collector of Internal Revenue for the District of Georgia.
3. On September 27, 1945, the Commissioner of Internal Revenue, in a ninety-day letter addressed to plaintiff, determined an estate tax deficiency for the estate of Otto Schwab in the amount of $17,105.58. This determination was based...
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