John David Smith, of the Estate of Louis R. Smith, Deceased v. United States

KING, Chief Judge:

Appellant John David Smith, Executor of the Estate of Louis R. Smith, brought suit against Defendant United States of America seeking a refund of federal estate taxes. The Estate claimed it was owed a partial refund because it overvalued certain retirement accounts held by the decedent in calculating the total gross estate and, therefore, overpaid its federal estate taxes. According to the Estate, the retirement accounts should have been valued at a discounted amount to reflect the federal income tax liability that will be triggered when distributions are made from the…