BURNETT, Justice.
We find in the record a succinct, well stated memorandum of the Chancellor, which we adopt as ours in deciding this case. This memorandum is:
"This is a suit to recover a portion of the inheritance tax paid under protest to the State of Tennessee by the complainant as executor of the estate of Louise P. Erskine.
"Louise P. Erskine, a citizen and resident of Shelby County, Tennessee, died testate in said county, and the complainant...
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