WILLIAMS, Judge.
The plaintiffs, executors of the estate of James L. Caldwell, deceased, seek recovery of $82,134.22, with interest thereon, alleged to have been overpaid by them on account of federal estate taxes imposed and collected under section 402 (a) of the Revenue Act of 1921 (42 Stat. 227, 278), which reads:
"That the value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real...
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