Court of Appeals for the Ninth Circuit August 7, 1985, 84-2477 (Jose De Oliveira, Jr., as of the Estate of Serafina De Oliveira v. United States)

SNEED, Circuit Judge:

Jose de Oliveira, Jr., executor of the estate of Serafina de Oliveira, appeals from a judgment entered in proceedings for the determination of entitlement to an estate tax refund. The district court held that estate taxes were properly assessed against Serafina’s estate and granted the Internal Revenue Service’s (IRS) motion for summary judgment.