GARWOOD, Circuit Judge:
This case involves the determination of the federal estate tax due from the estate of Elmore K. Melton, Jr. (Melton). On July 13, 1984, Melton, then age sixty, sold to his two adopted sons, John Wheeler and David Wheeler, the remainder interest in his ranch located in Bexar County, Texas. Melton retained a life estate in the ranch and used the actuarial tables set forth in the Treasury Regulations to determine the price to be paid by the Wheelers...
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