SEYMOUR, Justice.
This matter arises upon assessment of tax by the Succession Tax Division of the Bureau of Revenue of the State of New Mexico in the estate of Frank A. Stutzman, deceased, to which assessment, executrix filed objections. The matter was heard by the district court after removal from the probate court upon an agreed statement of facts.
The formal assessment of tax, insofar as relevant, is as follows:
"Valuation: Appraised value...
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