Rhode Island Hospital Trust Co. v. United States

DAY, District Judge.

Plaintiff in its capacity as the surviving executor of the estate of James C. Collins, who died testate on January 21, 1950, domiciled in Providence, Rhode Island, seeks to recover certain federal estate taxes and interest alleged to have been illegally assessed and collected from it as such executor. Plaintiff contends that the amount assessed and paid as federal estate taxes was excessive and illegal to the extent that the Commissioner of Internal Revenue erroneously refused (1) to credit said estate with the amount of succession taxes paid to the Dominion of Canada on…