United States Court of Claims December 23, 1983, No. 328-82T (Carmean v. United States)

OPINION ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

TIDWELL, Judge:

This is an action to recover $28,889.041 paid by plaintiff, in estate taxes, penalties and interest assessed to the estate of Ruth I. Carmean. Plaintiff and defendant have both moved for summary judgment.