AUGUSTUS N. HAND, Circuit Judge.
On March 14, 1925, the Commissioner of Internal Revenue assessed additional income taxes amounting to $139,750.66 against Elmer E. Smathers, of whose will the defendants became executors. Smathers thereafter filed a claim for the reconsideration of the assessment and the abatement of the tax, and as security for payment of such amount as, on reconsideration, might be found due, together with penalties, gave his personal bond for $150...
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