CHESNUT, District Judge.
The Commissioner of Internal Revenue made deficiency assessments for individual income taxes against the estate of Charles A. Penn of North Carolina in the amount of $12,369.50, plus interest for the calendar year 1930; and in the amount of $83,641.42, plus interest for the calendar year 1931 to October 22, when Charles A. Penn died. The executors of the estate paid these taxes, duly but unsuccessfully petitioned for a refund, and thereafter...
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