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OCR: Irvine, however that the adjustments required for her amended 1979 third-quarter gift tax return- which reported her partial diselaimer ft reduced the amount of unified credit available her result, she owed ar additional $44,035 in gift taxes for the 7JL.8 made in 1980. Mrs. Irvine paid the additional tax owed for 1980. plus $10 .959 ir aecrued interest (Pet. App. 31a-32a) Mrs. Irvine thereafter fled timely claim for re- fund quarter of of the gift pur tax the and third interest quarter paid for 1980 the third The 1979 claim for refund denied by the Jniernal Rev- enue Service (Pet. App 4a 32a After Mrs. Irvine's death in 1987, respondents who are the personal represen tatives of her estato -filed this action secking refund of the gift tax and interest paid. On cross-motions for summary jud ...