MORGAN, District Judge.
The above entitled action was submitted to this court upon stipulated facts and briefs.
Findings of Fact
1. Plaintiffs are executors of the Estate of Albert F. Meyer, who died September 14, 1952, having received Letters Testamentary as such executors from the Surrogate's Court of Erie County, New York, on October 9, 1952, and presently are acting as such executors.
2. This action arises under the Internal Revenue Code...
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