Virginia Hughes Chiles, of the Estate of Earle A. Chiles, Deceased v. United States

CANBY, Circuit Judge:

This is a tax refund case for the entire amount of federal estate tax assessed against and paid by the estate of decedent Earle A. Chiles. Virginia Hughes Chiles, executrix of the estate (“Estate”), appeals the district court’s summary judgment in favor of the Government. The Estate argues that the unlimited marital deduction for bequests to surviving spouses 1 precludes imposition of any federal estate tax in this case. Alternatively, the Estate claims that the assessment of federal estate taxes in this case violates the Uniformity Clause and the Fifth Amendment of the…