OPINION
BROCK, Justice.
The plaintiff, Bracey, brought this action to recover inheritance taxes levied against the estate of J.O. Paris and paid under protest. The theory of the plaintiff expressed in her complaint was that the defendant Commissioner had appraised the property of the estate at an excessive amount. The complaint also disclosed that the plaintiff had filed an appeal with the State Board of Equalization contesting the assessment and appraisal...
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