Mary Helen Parker and Jean Parker Griffith v. United States

RHOADES, Senior District Judge:

Appellants Mary Helen Parker and Jean Parker Griffith appeal from the decision of the district court granting summary judgment in favor of the United States. Appellants brought a refund claim for $90,000 in estate taxes paid by the estate of Appellants’ deceased stepfather, Edward Allison (“Stepfather”). 1 The taxes were paid from the corpus of a settlement trust of which Appellants were beneficiaries. The district court held that the doctrine of equitable recoupment applied, allowing the Government to retain the erroneously-paid tax. We reverse and hold that…