St. Clair v. United States

ORDER

ALSOP, Senior District Judge.

This matter comes before the Court on defendant United States of America’s Motion for Partial Summary Judgment pursuant to Federal Rule of Civil Procedure 56. In accordance with Federal Rule of Civil Procedure 78, the Court deems a hearing on the motion is not necessary and issues this Order based upon the materials submitted.

Defendant seeks partial summary judgment on plaintiff Matilda St. Clair’s action to obtain a refund of delinquency penalties assessed against the estate of Charles S. Elliot (the “Estate”) for failure to timely file its estate tax return…