EVANS, Circuit Judge.
Appellee brought this action to recover $24,401.68 and interest, which was the amount paid as taxes upon the income of P. A. Peterson for the year 1926. Judgment for said sum was duly entered, and this appeal followed.
P. A. Peterson will hereinafter be referred to as the deceased. He died June 9, 1927, before filing his 1926 income tax return. Appellee is his widow and was named as executrix of his estate, which was closed June 21, 1929...
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