LEAVELL v. KIEFFER

No. 98-4089.

189 F.3d 492 (1999)

Daniel R. LEAVELL and Eva L. Leavell, Plaintiffs-Appellants, v. Charles Michael KIEFFER, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 19, 1999.


Attorney(s) appearing for the Case

Christopher Heid (argued), Carmi, IL, for Plaintiffs-Appellants.

Kenneth L. Greene, Ellen P. DelSole (argued), Department of Justice, Tax Division, Appellate Section, Washington, DC, for Defendant-Appellee.

Before POSNER, Chief Judge, and EASTERBROOK and MANION, Circuit Judges.


EASTERBROOK, Circuit Judge.

Daniel and Eva Leavell, the proprietors of several businesses, did not file their 1985 and 1986 tax returns until 1990. An audit concluded that they owed substantial additional taxes. The Tax Court fixed their tax liabilities for 1985 to 1987 at approximately $1 million, including hefty interest and penalties. Leavell v. CIR, 71 T.C.M. 2387, 1996 WL 103805 (1996). One reason why the Leavells lost was that they did not produce essential...

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