MEMORANDUM DECISION
NICHOL, Chief Judge.
This case involves plaintiff's attempt to recover from the Internal Revenue Service a deficiency in the amount of $40,206.67 plus interest which plaintiff paid while reserving the right to institute this action.
Plaintiff, Bessie Craig, was appointed Executrix of the estate of her husband, Clarence Craig, who died as the result of an automobile accident on November 22, 1968. His gross estate was listed as...
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