Barbara Abrams, as of Lillian Hyman, Deceased v. The United States of America

KEARSE, Circuit Judge:

Plaintiff Barbara Abrams, suing as executrix of the estate of her mother Lillian Hyman, appeals from a judgment of the United States District Court for the Southern District of New York, Robert L. Carter, Judge, dismissing her complaint seeking a refund of $26,220 in estate tax assessed on Lillian Hyman’s estate and paid under protest. The district court granted the government’s motion for summary judgment dismissing the complaint on the ground that, within three years of her death, Lillian had paid some $67,000 to a bank on a debt incurred by her husband Charles Hyman,…