Estate of O'Neal v. United States

MEMORANDUM OPINION

PROBST, Senior District Judge.

This cause comes on to be heard upon cross-motions for partial summary judgment. Defendant United States of America (“the Government”) filed its motion on May 8, 2003 (Doc. 29). Plaintiffs filed their motions on May 9, 2003 (Docs. 32-34). 1

FACTS AND PROCEDURAL HISTORY 2

1. General Background

This case involves certain federal estate taxes on the estate of Kirkman O’Neal (“Mr. O’Neal”), deceased. Mr. O’Neal, founder of O’Neal Steel, Inc., died in Birmingham, Alabama on August 7, 1988. Prior to Mr. O’Neal’s death, he was married to Elizabeth…