Barbara B. Allbritton has sued the United States Internal Revenue Service (IRS) with the intention of recouping $40.6 million in taxes she and her family paid following the death of her husband, millionaire media mogul and banker Joe L. Allbritton in 2012.

As initially reported by Courthouse News, a “notice of deficiency” was delivered to Allbritton in 2013 related to what the IRS termed “taxable dividends” and distributions of art and antiques from his private holding company, Perpetual Corp. The tax agency believed Joe Allbritton received the distributions between 2005 and 2008.

Barbara Allbritton says that she paid the full $40.6 million tax bill “under protest.” The lawsuit is intended to initiate a refund of that sum from the IRS.

All told, 33 artworks were said to have been distributed to Allbritton over the four year period. The group includes pieces by Paul Cezanne, Winslow Homer, Paul Gauguin, Pablo Picasso, Claude Monet, and Vincent van Gogh, among others. According to the agency, the total value of the artworks was $139 million.

However, the widow contends that the ownership of the artworks never transferred from Perpetual Corp. to her late husband. Allbritton’s complaint, launched with the permission of her co-executor of Joe Allbritton’s estate, son Robert Allbritton, states, “There is not a single bill of sale, sales slip, invoice, purchase agreement, ownership transfer document, or anything else reflecting a sale or transfer of the art from Perpetual to Joe L. Allbritton in 2005.”

What the IRS calls “taxable dividends” were in fact payments made on the order of $364,000 to defray the cost of insuring the artworks. The IRS claims those payments were made to the Allbrittons. Again, Barbara Allbritton’s claim suggests no such payments were made to their account. “There could be no dividend because the payment was properly for Perpetual’s benefit,” the complaint states.

For its part, the IRS said in a statement to Courthouse News that it hadn’t yet had the opportunity to fully review the case but that upon doing so, they say, “We will consider our options and respond as appropriate with the court.”