ESTATE OF LILLEHEI v. C.I.R.

No. 80-1380.

638 F.2d 65 (1981)

ESTATE of Clarence I. LILLEHEI, deceased. James P. LILLEHEI, Executor, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided January 28, 1981.


Attorney(s) appearing for the Case

Richard D. Bunin, Minneapolis, Minn., for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Michael L. Paup, Gary R. Allen, Jo-Ann Horn, Attys., Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before HEANEY, ROSS and ARNOLD, Circuit Judges.


PER CURIAM.

Appellant James P. Lillehei challenges the United States Tax Court's decision that he as executor of the Estate of Clarence I. Lillehei did not show reasonable cause for the late filing of the estate's federal estate-tax return.

This action was brought by the executor in the United States Tax Court to abate the assessment of penalties imposed by the Commissioner of Internal Revenue for late filing under sections 6651(a)(1) and (2) of the Internal...

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