CONNOR, District Judge.
This is an action by the administrator de bonis non of the estate of Madeleine V. Chandler, for refund of federal estate taxes alleged to have been erroneously paid. The controversy revolves on the question of ownership of 172 common shares of the stock of American Telephone and Telegraph Company and six shares of the stock of Northern Railroad. The plaintiff claims that the stock at all times belonged to him, while the
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