Crisp v. United States

OPINION

ANDEWELT, Judge.

I

In this tax refund action, plaintiff, Don W. Crisp, trustee of the Caroline Hunt Trust Estate (the Trust or Trust Estate), seeks a refund of $2,993,572.811 for income taxes the Trust allegedly overpaid for the tax year ending June 30, 1987, and the shortened tax period ending December 31, 1987.2

In 1935, Caroline Hunt’s parents, H.L. and Lyda Hunt, established the Trust Estate through an “Articles of Agreement and Declaration of Trust” (the Trust Agreement). The Trust Agreement provides that the trustee may, at his or her discretion, make periodic payments to Caroline…