US Bank, N.A. v. United States

MEMORANDUM AND ORDER

BATAILEON, District Judge.

This matter comes before the Court on the defendant’s motion to dismiss for failure to state a claim (filing 13). The plaintiffs have opposed the motion. Both parties have briefed the issues. Following the Court’s review of the pleadings, briefs and case law, the Court will grant the defendant’s motion to dismiss the plaintiffs’ complaint pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure.

I.Factual Summary

On April 14, 1993, Ruth S. Dinsmore died. At the date of her death, the maximum federal estate tax rate was 50%. In August 1993,…