O'SCANNLAIN, Circuit Judge:
We consider whether retroactive application of an amendment to the federal estate tax portion of the Internal Revenue Code violates due process.
I
On October 22, 1986, the Tax Reform Act of 1986 ("TRA") became law. One provision of the TRA allowed an estate to deduct half of the proceeds of a sale of securities to an Employee Stock Ownership Plan ("ESOP") from a decedent's gross estate ("the ESOP proceeds deduction")....
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