Laura Sue Durrenberger Smith, and Martha Durrenberger McKnight Plaintiffs v. Gary Booth, District Director, I.R.S., and the United States of America

Plaintiffs appeal the district court’s entry of judgment adverse to their claims for declaratory and injunctive relief against the United States Internal Revenue Service. Finding that the district court was without jurisdiction to entertain the plaintiffs’ claims, we reverse the judgment of the district court.

I

The plaintiffs in the instant case are the executors of the estate of Camilla Durren-berger. At the time of her death, Ms. Durrenberger owned five parcels of property, one of which was located at her residence in Williamson County, Texas, the other four of which were located in Coleman…