HARRIS, Associate Judge:
The District of Columbia appeals from the trial court's ruling that the District must refund $10,125.15 (plus $405 interest) representing inheritance tax paid under protest by the estate of Lulie Dickson. Finding that the tax was properly assessed, we reverse.
I
The principal facts are not in dispute. The decedent, Lulie Dickson (Lulie), and her brother, Waverly W. Dickson (Waverly), formed a partnership in 1935, using the...
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