OPINION AND ORDER
BIUNNO, District Judge.
Nature of Case
In this case, Connelly sues to recover the sum of $3,200., plus statutory interest from June 7, 1968, paid under protest as the result of an assessment calculated on the basis of including in Connelly's taxable estate the commuted value of installments payable to decedent's son under a group life insurance arrangement provided by Connelly's former employer.
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