OPINION
CAFFREY, District Judge.
This is a civil action to recover estate taxes and assessed interest in the amount of $831,608.31, together with statutory interest thereon. Jurisdiction of this court is based upon 28 U.S.C.A. § 1346 (a) (1).
Plaintiff, Old Colony Trust Company, a Massachusetts corporation, is the duly qualified executor under the will of Charlotte E. Sills, who died on January 26, 1961. The will was admitted to probate in the...
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