OPINION
BREWSTER, District Judge.
Sid W. Richardson Foundation brought this suit to recover a total of $769,711.48 income taxes and interest assessed against and paid by it for the fiscal years ended September 30, 1960, and September 30, 1961, as the transferee of the residuary assets of the estate of Sid W. Richardson, deceased.
All prerequisites for the maintenance of this action have been met, and the Court has jurisdiction under 28 U.S. C.A....
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