MEMORANDUM AND ORDER
OWEN D. COX, District Judge.
The Plaintiff, First Victoria National Bank, Independent Executor under the Will of T. J. Babb, Deceased, has filed this suit for refund of estate taxes paid under protest to the Defendant, United States of America. Plaintiff alleges that the taxes were illegally collected because the Internal Revenue Service erroneously included in the taxable estate of T. J. Babb 1142.6 acres of producer rice allotment...
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