Sylvia M. Buckmaster, as Personal Representative of the Estate of Daisy Murphy, Deceased v. United States

LOGAN, Circuit Judge.

Sylvia M. Buckmaster, in her capacity as personal representative of the Estate of Daisy Murphy, deceased (the estate), appeals the district court’s grant of the government’s motion for summary judgment in the estate’s suit for refund of income taxes levied by the Internal Revenue Service (IRS). The only issue on appeal is whether the estate is entitled to claim a deduction under I.R.C. § 661 for income it distributed to estate beneficiaries during two of the estate’s tax years. The disbursements were made without explicit authority under the will and without any prior…