SOPER, Circuit Judge.
This suit was brought by Flora F. Herring, administratrix of the estate of W. A. Herring, her deceased husband, against the United States to secure a refund of income taxes which had been paid by the estate after the decedent's death. W. A. Herring died on July 18, 1948, leaving a gross estate of $230,387.94. On July 12, 1949, the administratrix made an estate tax return showing a 1949 estate tax liability of $28,280.63, which she then paid;...
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