OPINION.
HARRON, Judge:
The income tax liability for 1951 of the petitioner's deceased husband, Samuel Lewis, has not been paid because the assets of his estate were insufficient to meet this liability. He was, at the time of his death, an employee of the City of New York and a member of the New York City Employees' Retirement System. Upon her husband's death the petitioner was entitled to receive from the retirement system, as the duly designated...
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