Ennis L. Mazza, of the Estate of Raymond J. Mazza, Deceased v. Olga M. Mazza

McGOWAN, Circuit Judge:

R. J. Mazza died a resident of Maryland, leaving a will which named appellant — his wife, Ennis Mazza — executrix and sole beneficiary, and which made no provision for the payment of the federal estate tax. The decedent and appellee —his sister, Olga Mazza — held real property in the District of Columbia as joint tenants with rights of survivorship. 1 That property passed to appellee by operation of District of Columbia law, and was included in R. J. Mazza’s taxable estate under § 2040 of the Internal Revenue Code of 1954. Appellant paid the entire federal estate tax,…