TAYLOR, District Judge.
Some eighteen months before the death of Morgan Llewellyn, which occurred February 17, 1920, he divided $40,000 of his estate between his children and his wife.
After his death, the defendant included this amount as a part of the gross estate in computing the estate tax, and collected the sum of $1,263.84, as shown by stipulation of the parties, more than would have been collected had this amount been deducted...
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