SWEENEY, Chief Judge.
In this case plaintiff sues for a refund of estate taxes in the amount of $148,291.49 plus interest, which sum it claims was illegally collected by the government. The action stems from a determination by the Commissioner that the amount of $395,377.54, representing a remainder interest of three-quarters of the residue left in trust under the will of Courtenay Guild, did not constitute an allowable deduction under § 812(d) of the Internal...
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