OPINION
NOONAN, Circuit Judge.
Robert H. Bachler ("the Executor"), executor of the estate of E. Murielle Wunderlich, appeals the judgment of the district court for the Northern District of California denying his suit for refund of estate tax erroneously paid pursuant to Internal Revenue Code § 2612(c). We hold that the tax was paid upon a transfer of property by a general power of appointment under a trust that became irrevocable in 1976, and was therefore...
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