The Hibernia Bank, Administrator With the Will Annexed of the Estate of Celia Tobin Clark, Deceased v. The United States of America

WALLACE, Circuit Judge:

The Hibernia Bank (Hibernia) appeals from a judgment of the district court denying its claim for a refund of federal estate *742taxes. This appeal squarely presents an important issue of estate tax law which has engendered a crisp conflict among the circuits. We affirm.

I

In May 1965, Celia Tobin Clark died testate leaving an estate worth several million dollars. Mrs. Clark’s will provided for several specific bequests of personal property. The will also directed that the residue, which included the bulk of the estate, be divided among four testamentary trusts. The income of…