First Wisconsin Trust Co. v. United States

DECISION AND ORDER

REYNOLDS, Chief Judge.

This is an action brought pursuant to 26 U.S.C. § 7422(a) and (f)(1) for the recovery of $591,888.25 in gift and estate taxes, plus interest, paid by the plaintiff First Wisconsin Trust Company as personal representative of the Estate of Patricia A. Jansen. The court has jurisdiction under 28 U.S.C. §§ 1340 and 1346(a)(1). Currently pending before the court are the plaintiff’s motion for summary judgment and the defendant’s motion for partial summary judgment. For the following reasons, the plaintiff’s motion will be granted and the defendant’s motion…