CLAY, Commissioner.
This is an appeal from a judgment construing the will of C. L. Forman, and reversing a ruling of the Department of Revenue relative to an inheritance tax assessment.
In 1947 Lillie B. Forman died, and her executor listed as part of her estate an 815 acre farm which had been devised to her under the will of her husband, C. L. Forman. This will provided, so far as pertinent here (our italics):
"Second, I will all of my real estate...
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