Emil L. Jeschke, of the Estate of Emil J. Jeschke, Deceased, Ida G. Jeschke, and Myron Jeschke v. United States

STEPHEN H. ANDERSON, Circuit Judge.

The estate of Emil J. Jeschke appeals from an adverse judgment by the District Court in a federal estate tax refund suit filed by the estate. Upon audit of the federal estate tax return filed by the estate the Internal Revenue Service (“IRS”) assessed a deficiency of $11,297.22 plus $2,766.14 in interest based mainly upon three adjustments: (1) inclusion in the gross estate of interest, unmatured and forfeitable prior to death but maturing on death, arising from certificates of deposit purchased and held by the decedent in joint tenancy; (2) a determination…