KERRIGAN, District Judge.
This is an action by the executors of the estate of Christine F. Rengstorff, deceased, to recover $5,400 paid under protest as a tax on property valued at $210,000, which plaintiffs claim was erroneously included in the estate of the deceased upon a reassessment thereof by the Commissioner of Internal Revenue.
The record shows that the property in question was transferred on June 19, 1912, in three equal parts, each worth $70,000...
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