Plaintiff - Appellant:
John Keith Blakley, Rhonda L. Blakley, The Estate of John E. Long
Steven T. Miller, Acting Commissionerof the U.S. Internal Revenue Service, in his official capacity
Defendant - Appellee:
Jacob E. Lew, Secretary of the U.S. Department of Treasury, in his official capacity, Daniel Werfel, Acting Commissioner of the U.S. Internal Revenue Service, in his official capacity,
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