MEMORANDUM OPINION
BRATTON, District Judge.
This is an action by Mrs. Ruth Wilson Hurley for the recovery of Federal Estate Taxes in the amount of $238,236.33 paid under protest by her, pursuant to an assessment for estate taxes in connection with the death of General Patrick J. Hurley. Prior to the death of General Hurley on June 30, 1963, he and Mrs. Hurley were residents of and domiciled in Santa Fe, New Mexico. They owned community property governed...
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