MEMO DECISION
POWELL, Chief Judge.
This action was instituted to recover a tax refund. It is based on stipulated facts appearing in the pretrial order. This Court has jurisdiction under 28 U.S.C. 1346(a) (1).
The plaintiff is Martha A. Willging. She brings the action individually and as executrix of the estate of John Z. Willging, deceased. The date of his death was November 15, 1966.
The plaintiff and the decedent owned a grain farm near...
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