LUMBARD, Circuit Judge:
Esther Minskoff, the executrix of the estate of Sam Minskoff, brought this suit on October 9, 1964 for the recovery of certain income taxes assessed against Sam Minskoff's 1949 income and paid by the estate in 1961 and for the recovery of a portion of the estate tax paid on Sam Minskoff's estate in 1953 and 1955. The plaintiff alleged three causes of action, the first asserting an overvaluation of the gross estate...
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