DAHLING, J.
This is an appeal from the Probate Division of the Court of Common Pleas of Geauga County, wherein the court entered its final order overruling the ancillary administrator's and executor's exceptions to the Tax Commissioner's Certificate of Determination of Ohio Estate or Additional Tax.
The facts are that Mrs. Flora M. Hosmer, a New York state resident, expired on September 9, 1978. She owned extensive land holdings in both Lake and Geauga Counties...
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