MEMORANDUM OF DECISION
KUNZEL, Chief Judge.
This case is submitted in the main on stipulated facts. Evidence was taken only on some limited issues which will be hereafter mentioned.
Plaintiffs seek a refund of taxes paid to the United States. This court has jurisdiction by virtue of 28 U.S.C.A. § 1346(a) (1).
Harold L. Pope, referred to as decedent, died on April 3, 1962. Up until the time of his death he was the holder of a life estate...
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