Sue Ann Hunter, Marie Joyce Kotsonis, L. Fargo Richardson and the L. F. Richardson Foundation v. The United States of America

STEPHENSON, Circuit Judge.

The United States appeals from the district court’s 1 order granting the plaintiffs-appellees’ motion for summary judgment. Judgment was entered in favor of the plaintiffs — the sole distributees and beneficiaries under the last will and testament of Lloyd F. Richardson, deceased — entitling them to obtain a refund of federal estate taxes which the district court ruled were erroneously assessed against them. On appeal the government argues that the district court erred in holding that proceeds from insurance policies on the decedent’s life were not includable in his…