BELL, District Judge.
This is an action for a refund of a portion of the taxes paid on the estate of the late Frank B. Kellogg. The decedent, hereinafter called the testator, bequeathed to the Protestant Episcopal Cathedral Foundation of the District of Columbia, a religious organization, the sum of $100,000 and to the University of Minnesota, an educational institution, the sum of $25,000 to be used in making loans to needy students. As to these bequests the will...
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