Estate of Piper v. United States

OPINION ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT ON THE ISSUE OF LIABILITY AND PLAINTIFFS’ CROSS-MOTION FOR SUMMARY JUDGMENT

PHILIP R. MILLER, Judge:

This is a suit for interest of $104,461 on overpayments of gift and estate taxes, in which the government has counter-claimed for $125,201 in unpaid gift taxes and $1,217,613 in erroneously refunded estate taxes, plus interest.

Although the figures are complex, the issues may be simply stated. The taxpayer was assessed for a deficiency in estate taxes and chose to pay it, as permitted by law, by redeeming unmatured United States 3V2 percent…