CUTTER, J.
The petitioner (hereinafter called the executrix) was appointed executrix of the will of Cyrus A. Stow (hereinafter called the testator) on December 4, 1952. The commissioner of corporations and taxation (hereinafter called the commissioner), acting through a subordinate officer of his department, on October 10, 1955, sent to the executrix a notice of proposed assessment of additional income taxes for the years 1951 and 1952, based upon alleged inaccuracy...
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