Estate of O'Neal v. United States

MEMORANDUM OPINION

JOHNSON, District Judge.

Currently before the Court are cross-motions for summary judgment as to the claims asserted by plaintiffs and the counterclaims asserted by defendant (docs. 24 and 26). This court heard oral argument on the motions and has reviewed the mem-oranda of law and evidence submitted by the parties. The facts before this court are as follows:

Plaintiffs filed this lawsuit to obtain a refund of $1,883,762.00 in federal estate taxes and interest collected from the Estate of Elizabeth P. O’Neal, deceased. The refund is based upon claims made against plaintiffs…