In re the Estate of Owen

S. Samuel Di Falco, S.

The principal question raised by objections to the account of the executor is whether the United States estate tax should be allocated against -legacies bequeathed in the Mexican will of the decedent. The parties have agreed *181to submit the matter on affidavits without formal hearing. The facts, except for opinions on Mexican law, are not in dispute.

The decedent was a citizen of the United States, domiciled in Mexico City, who possessed substantial assets in New York and in Mexico. On May 14, 1965 she executed a will in New York which disposed of all of her property “…