SWYGERT, Senior Circuit Judge.
The executors of the estate of Richard S. Ekins sought a reconsideration in the United States Tax Court of a deficiency in decedent's tax return as determined by the Commissioner of Internal Revenue. The Tax Court rejected petitioners' argument that retroactive application of the provisions of section 2035 of the Internal Revenue Code of 1954, as amended by the Revenue Act of 1978, was unconstitutional. Petitioners now appeal that holding...
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