SCHROEDER, Circuit Judge.
The estate of David Ray brought this action in the district court to recover the estate tax and interest paid on a one-half interest in a trust established pursuant to a divorce settlement. The district court denied the refund. It held that the one-half interest was properly included in the estate pursuant to 26 U.S.C. § 2036(a) because the decedent retained a life estate in the property transferred to the trust, and the estate failed...
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