WISDOM, Circuit Judge:
This appeal arises from the Government's efforts to recoup a small portion of the millions of dollars in taxes owed and never paid by Billie Sol Estes and his wife, Patsy D. Estes ("the taxpayers"). The taxpayers filed joint returns for each of the calendar years 1959, 1960, and 1961. The Tax Court determined that Patsy D. Estes was liable for tax deficiencies for those years of more than 9 million dollars. Patsy D. Estes v. C. I. R., No. 245...
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