JONES, Circuit Judge.
The Internal Revenue Service of the United States made assessments against the appellee, Scott W. Allen, Jr., and Frances Allen, his wife, for $270,066.13, and against the appellee individually for $155,819.92, plus interest. Scott W. Allen, Jr., was a beneficiary of the estate of his mother in the amount of $40,000.00, or more. The Fulton National Bank of Atlanta, Georgia, is the executor of the mother's estate. On June 9, 1960, a bill of complaint...
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