Estate of Palumbo v. United States

MEMORANDUM OPINION

ARTHUR J. SCHWAB, District Judge.

Before the Court are the parties’ cross-motions for summary judgment. The Estate of Antonio Palumbo and its Executor (hereinafter “Plaintiff’) brought this action seeking a refund (plus accrued interest) of an alleged overpayment of Federal estate taxes. Plaintiff paid federal estate taxes on an amount — $11,721,141.00 — which was paid to a charitable trust created by Mr. Palumbo during his lifetime. This payment was made to the charitable trust under the terms of a settlement agreement negotiated (primarily) between Mr. Palumbo’s son and…