
    ESTATE OF Earl C. KOESTER, Deceased, Carol C. Fortney and Roger D. Fortney, Personal Representatives, Petitioner — Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent— Appellee.
    No. 02-71663.
    Tax Court No. 530-00.
    United States Court of Appeals, Ninth Circuit.
    Submitted Feb. 10, 2003.
    
    Decided Feb. 19, 2003.
    Before LEAVY, FERNANDEZ and BERZON, Circuit Judges.
    
      
       This panel unanimously finds this case suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).
    
   MEMORANDUM

The Estate of deceased Earl C. Koester, through personal representatives Carol and Robert Fortney, appeals pro se the decision of the Tax Court denying the Estate’s petition for redetermination of estate tax liability. The Fortneys contend that the Estate should be excused $155,000 in estate tax liability because imposition of the tax violates the deceased’s equal protection rights since he had been educationally handicapped which hindered his understanding of estate planning. We affirm for the reasons stated in the Tax Court’s opinion issued on March 28, 2002.

AFFIRMED. 
      
       This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by Ninth Circuit Rule 36-3.
     