OPINION
Opinion by: STEVEN C. HILBIG, Justice.
This is an appeal from the probate court's judgment construing section 2603(b) of the Internal Revenue Code and provisions in the will of Gilbert M. Denman, Jr. ("the Will") to determine the proper allocation of the federal generation-skipping transfer tax ("GST tax"). Appellants Leroy G. Denman, Jr., as independent coexecutor ("Denman"), and Wendel
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