BIRCH, Circuit Judge:
This case presents three challenges by the appellant, Richard M. Baptiste ("Baptiste"), to the tax court's grant of summary judgment to the government. Initially, Baptiste argues that his status as a transferee of an estate must be decided under state law and that genuine issues of material fact remain as to that issue. Next, he contends that the tax court erred in applying the doctrine of res judicata to him, a transferee of an estate, on the...
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