Estate of O'Neal v. United States

MEMORANDUM OPINION

JOHNSON, District Judge.

This case is before the Court on remand from the Court of Appeals for the Eleventh Circuit for further consideration consistent with its opinion in O’Neal v. United States, 258 F.3d 1265 (11th Cir.2001), affirming in part, vacating in part, and remanding with instructions this Court’s decision reported at 81 F.Supp.2d 1205 (N.D.Ala.1999).

The central issue in this case involves the estate tax deduction by the Estate of Elizabeth P. O’Neal, deceased, (“Mrs. O’Neal’s Estate”) under 26 U.S.C. § 2053(a)(3) for claims against Mrs. O’Neal’s Estate resulting…