OPINION
ROSENBERG, District Judge.
The plaintiffs, John G. Buchanan, John G. Buchanan, Jr. and Mellon National Bank and Trust Company, Executors of the Estate of Mabel Lindsay Gillespie, claim of the defendant, the United States of America, the sum of $21,089.71 as the erroneous sum of money which they paid to the Internal Revenue Service in accordance with its demand. The matter was submitted on briefs and the facts are undisputed.
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