STRUM, Circuit Judge.
This is an action to recover an overpayment of federal estate tax, erroneously collected. The United States admits the overpayment, but resists restitution on the ground that the taxpayer is barred by 26 U.S.C.A. § 910, which fixes a three year period of limitation for such claims. The specific question before us is whether or not, as the United States
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