Court of Appeals for the Eighth Circuit December 28, 1992, No. 89-5616 (Irvine v. United States)

lead-opinion

BOWMAN, Circuit Judge.

The United States appeals from the order of the District Court granting summary judgment in favor of John O. Irvine and First Trust National Association (taxpayers) as the personal representatives of the Estate of Sally Ordway Irvine (Mrs. Irvine) and directing the government to refund federal gift taxes and interest paid by Mrs.