Cleveland Trust Co. v. United States

*826MEMORANDUM

WILLIAM K. THOMAS, District Judge.

Defendant United States of America moves for summary judgment dismissing Counts II, III, and IV of the plaintiffs’ complaint. Count I, not involved in the present motions, asks refund of an additional estate tax of $475,848.95 paid in full on May 22, 1963 by the executors of the Estate of Helen Wade Greene, deceased, and interest of $90,131.25 paid in full on August 12, 1963. Helen Wade Greene died on December 24, 1958.

The additional estate tax was assessed upon property in the amount of $1,322,-580.70 conveyed by the decedent, Helen Wade Greene, to…