Parrott

John Parrott, the immediate decedent, hereinafter called “decedent,” died testate January 20, 1918. His mother, Abby M. Parrott, referred to hereafter as “prior decedent,” died, testate, October 6, 1917, decedent being a beneficiary under her will, resulting in his inheritance of real and personal property to the value of $519,919.52. This value formed part of the gross estate of the prior decedent and federal tax paid thereon, and also formed part of the gross estate of decedent. In addition to the inheritance so valued, the other gross estate of decedent, consisting entirely of personal property, was valued, on audit of the Internal Revenue Commissioner, at $1,428,596.15.

The federal estate tax return by the executors of decedent, showing net estate $1,137,984.10., was accompanied by payment of tax of $98,558.09. The audit of the Comm.is-missioner found a net estate of $1,378,596-15, with an additional tax of $28,873.45. April 23,1923, the executors paid $21,880.36 thereof, and the balance, $6,993.09 with $1,109.63 interest ($8,102.72), under protest, November 25, 1924, with claim for abatement and claim for refund thereof as taxes illegally collected. These claims were finally…