WISDOM, Circuit Judge:
This taxpayer's suit for an estate tax refund grew out of executors' settling for $42,000 an estate's claim for an income tax refund of $60,000, listed in the estate tax return as having "no value" at the date of the decedent's death.
The decedent, B. Hill Simmons, died December 27, 1955. Some time before his death, the Internal Revenue Service began investigating, on a net worth basis, Simmons's income tax returns for the years 1941...
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