“ The sole question for decision is: Was the estate tax paid by the executors, and claimed by them as a deduction in the income tax return for the year 1918, an allowable deduction in ascertaining the net taxable income of the estate for that year? ”

“ Had the deduction been allowed, there would have been no taxable net income for that year, and no part of the $165,075.78 would have been collectible. Payment of that sum, as so assessed, was pressed on the executors, and they paid it under duress. ”

“ Indeed, the same act, by sections 400-410 (Comp. St. Ann. Supp. 1919, §§ 6336 3/4 a-6336 3/4 k) , expressly provides for their continued imposition and enforcement. Thus their omission from the excepting clause means that Congress did not intend to except them. ”