BOURQUIN, District Judge.
Plaintiff sues to recover part of gift taxes by her paid, on the theory that by mistake she had over-valued the gift.
It appears that in 1924 she and her son George incorporated the Whittell Investment Company to hold, manage, and own their properties by them, and as heirs derived from and in the estate of her deceased husband, distributed and undistributed. To that end they took to themselves all the capital stock of said corporation...
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