Goudy

851 F.2d 360 Unpublished Disposition NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Grace C. GOUDY; Maribeth W. Collins, Esq.; Eugene E. Sharp; and United States National Bank of Oregon, Personal Representatives; Estate of Alton L. Collins, Deceased; Grace C. Goudy & Maribeth W. Collins, United States National Bank of Oregon, Trustee Under Article V of the Last Will of Alton L. Collins, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant. No. 86-4402. United States Court of Appeals, Ninth Circuit. Argued and Submitted March 10, 1988. Decided June 28, 1988. Before GOODWIN, NELSON and LEAVY, Circuit Judges. 1 MEMORANDUM * 2 The government appeals a summary judgment awarding a refund of $599,832.94 in federal estate taxes plus interest. The district court concluded that the partial disclaimer of a general power of appointment was effective, thereby avoiding federal estate tax consequences pursuant to I.R.C. Sec. 2041 (1954) and Treas.Reg. Sec.…