PELL, Circuit Judge.
Lurline Smith died on July 14, 1958. A federal estate tax return was filed but the tax was not paid. In 1964, the state probate court entered a judgment against the estate for the taxes which had been assessed. On August 25, 1965, the Government filed suit in the district court to foreclose federal tax liens. The only property involved in that suit which is also involved in the present appeal was real estate in which the decedent was a joint owner...
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