OPINION
COOLAHAN, District Judge:
Plaintiff, executor of the estate of Hamilton Gray, brings this action to recover estate taxes, together with interest as provided by law, which he claims were erroneously and illegally assessed and collected by the defendant from the estate. The deceased, Hamilton Gray, died in 1958. At the time of his death, he was an employee of the Socony Mobil Oil Company (hereinafter referred to as "Socony"), a New York Corporation...
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