CHASE, Circuit Judge.
When Frank D. Waterman died in 1938, he left as part of his estate, of which Frank S. Waterman is the sole surviving executor and the petitioner herein, a non-interest bearing bill of exchange for ten thousand pounds signed by L. G. Sloan, Ltd., of London, England. That bill of exchange was valued for estate tax purposes at $46,806.94.
In 1945, the obligation was paid by depositing ten thousand pounds to the credit of the petitioner in...
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