Zabel v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

KOPF, District Judge.

Following a bench trial and subsequent briefing by the parties, I now issue my findings of fact and conclusions of law in accordance with Federal Rule of Civil Procedure 52(a). For the reasons set forth below, I find and conclude that judgment should be entered for the United States. 1

I. BACKGROUND

The plaintiff seeks a refund of federal estate tax and interest paid by the estate of Beulah G. Palmer (“the Estate”) because of Defendant’s denial of a charitable estate tax deduction to the Estate. Specifically, the Estate claims that 26…