PALMIERI, District Judge.
The plaintiff, as administratrix of the estate of a deceased transferee, seeks a refund for interest paid on the decedent's transferee tax liability. The transferee's liability was assessed and paid pursuant to Int.Rev.Code of 1954 § 6901, 26 U.S. C.A. § 6901, which provides a summary method of collecting the amount of "the liability, at law or in equity, of a transferee of property * * * of a taxpayer * * *." See Phillips v. Commissioner...
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