JAMES C. FOX, District Judge:
This is a suit for the refund of $124,311 in estate taxes, penalties, and interest, assessed and collected by the Internal Revenue Service from the Estate of William H. Wisely. In the district court, judgment was for the United States and the taxpayer estate has appealed. The principal question for our determination is whether the district court properly granted summary judgment for the government in holding that the deceased's will,...
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