HARVEY, District Judge:
The executors under the will of Gage B. Ellis ("the decedent") here seek to recover estate taxes in the amount of $153,251.10, together with $30,513.42 statutory interest thereon, paid by them to the District Director of Internal Revenue. Of this amount, $149,623.93 and all of the statutory interest were paid as additional estate taxes and interest following an audit of the decedent's estate tax return and a deficiency assessment by the District...
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