COFFEY, Circuit Judge.
This is an appeal from a decision of the district court denying the appellant's request for a federal estate tax refund. The Internal Revenue Service ("IRS") assessed a deficiency of $25,657 plus interest of $4,985 against the plaintiff-appellant, Independence Bank of Waukesha ("Bank"), the personal representative of the Estate of Mary C. Walter. There was no dispute as to any material fact and both parties moved for summary judgment in the...
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