CHOY, Circuit Judge:
Introduction
Plaintiffs-Appellants, members of the McKeon Family ("Estate"), appeal in this tax action the grant of summary judgment in favor of Defendant-Appellee United States of America ("Government"). The district court found that the Estate had overstated its marital deduction under I.R.C. § 2056.
We REVERSE.
Factual and Procedural Background
Marguerite B. McKeon ("decedent") died on April 27, 1994...
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