SMITH, District Judge.
This is an action by the executors of a decedent's will to recover $202,575.06, allegedly overpaid as estate taxes. The question at issue is whether the value, $583,648.61, of property on the date of the decedent's death, over which he had a general power of appointment, is includible in the value of the decedent's gross estate under Section 811(f), as amended, of the Internal Revenue Code, 26 U.S.C.A. § 811(f).
Prior to 1942, property...
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