United States v. Simmons
United States Court of Appeals for the Fifth Circuit
346 F.2d 213 (1965)
- Written by Daniel Clark, JD
Facts
The Internal Revenue Service (IRS) (defendant) audited the tax returns of B. Hill Simmons and found him to have underpaid his income taxes for several years. The IRS assessed a deficiency, which Simmons paid. Simmons had not contemplated challenging the IRS’s determination and suing it for a refund before he died. After Simmons died, the executors of his estate (plaintiffs) discovered evidence suggesting that the IRS’s determination may have been erroneous, and they sued the IRS for a refund. The refund claim was eventually settled out of court for approximately $41,000. The executors included the value of Simmons’s refund claim at zero dollars as of the time of his death. The IRS determined that the claim should be included in the gross estate at a value equal to the amount it was settled for. The executors sued the IRS in district court. The district court upheld a jury determination that the claim was valueless, and the IRS appealed.
Rule of Law
Issue
Holding and Reasoning (Wisdom, J.)
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