BORAH, District Judge.
This action was filed by the universal legatees and heirs of Sam Wiener, Jr., deceased, to recover an alleged overpayment of federal estate taxes in the amount of $162.329.59, with interest. The case was tried by the court without a jury on an agreed statement of facts. The stipulated facts, incorporated herein by reference, reveal the following:
Plaintiffs are the sons of Sam Wiener, Jr., who died on December 10, 1942, in Shreveport...
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