Boryan v. United States

MEMORANDUM OPINION

ELLIS, District Judge.

Introduction

In this estate tax refund suit, the central issue is whether the Internal Revenue Service (IRS) properly disallowed a Section 2013 credit in connection with the tax return for the estate of Jean Marston Glendening. See 26 U.S.C. § 2013. Plaintiffs are Mrs. Glendening’s sole beneficiaries. They contend the IRS erred in denying the credit. Indeed, they claim the refund should be even larger than the amount originally disallowed because Mrs. Glendening's executor relied on an IRS form that contained a printing error. The government counters…