MEMORANDUM
MEREDITH, District Judge.
This is a suit under 26 U.S.C. § 7422 for the recovery of estate taxes paid to the Commissioner of Internal Revenue as a result of an allegedly erroneous or illegal assessment. This Court has jurisdiction under the provisions of 28 U. S.C. § 1346. The cause was submitted on the stipulated facts, which are incorporated herein by reference, and briefs submitted by both parties. Particular facts will be set forth...
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