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ESTATE OF SOWELL v. U.S.

No. 98-11066.

198 F.3d 169 (1999)

ESTATE OF Willie Mae SOWELL, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

December 13, 1999.

Attorney(s) appearing for the Case

G. Tomas Rhodus (argued), Looper, Reed, Mark & McGraw, Dallas, TX, for Plaintiff-Appellant.

John A. Nolet (argued), Jonathan S. Cohen, U.S. Department of Justice, Tax Division Appellate Section, Washington, DC, for Defendant-Appellee.

Before KING, Chief Judge, and REYNALDO G. GARZA and EMILIO M. GARZA, Circuit Judges.

EMILIO M. GARZA, Circuit Judge:

The Estate of Willie Mae Sowell ("the Estate") appeals from a jury verdict upholding an IRS penalty for the Estate's failure to establish "reasonable cause" for its late payment of estate taxes. We affirm.

I.

Willie Mae Sowell passed away on December 14, 1991, at the age of 99. At the time of her death, most of Sowell's substantial fortune was consolidated in two trusts.1

Federal...

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