MEMORANDUM
AUSTIN, District Judge.
This action was brought by the executors of a decedent's will to recover federal estate taxes they paid on life insurance proceeds received by the defendant who is also a beneficiary of $125,000.00 under the will. Earlier, defendant's motion to dismiss for lack of subject-matter jurisdiction was denied, since plaintiffs' claim arises from the Internal Revenue Code of 1954, § 2206.
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