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OCR: IN THE COURT HF UNTTED STATES October Term 1993 UNTTED STATES OF AMERICA, Petitioner JOHN IRVINE and FIRST TRUST NATIONAL ASSOCIATION. Respondents ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT BRIEF OF RESPONDENTS This is an action for refund of $7 .530,706. .90. plus statutory interest, in federal tax erroneously assessed against and collected From Sally Irvine. involves the effectiveness federal ax purposes Mrs Irvine's written Disclaimer portion remainder interest the Ord lway Trust The Trust was Created by her grandfather Lucius Ordway in 1917 fifteen years before enactment federal Gift Mrs Irvine died ir 1987 and Res spondents John Irvine and Trust National Assoclation are co-representatives her Estate, the successor- r-in-interest to her refund cl ...