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ESTATE OF LISLE v. C.I.R.

Nos. 01-60639, 01-60640, 01-60641 and 01-60642.

341 F.3d 364 (2003)

ESTATE OF Robert W. LISLE, Deceased; Estate of Donna M. Lisle, Deceased, Petitioners-Appellants, Thomas W. Lisle, Independent Co-Executor; Amy L. Albrecht, Independent Co-Executor, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 30, 2003.

Attorney(s) appearing for the Case

Vester T. Hughes, Jr. (argued), Robert Edwin Davis, David John Schenck (argued), Hughes & Luce, Dallas, TX, Royal Bernard Martin, Jr., Steven Spencer Brown, Martin, Brown & Sullivan, Chicago, IL, for Petitioners-Appellants and Appellants.

Joan I. Oppenheimer (argued), Kenneth L. Greene, Steven W. Parks (argued), U.S. Dept. of Justice, Tax Div., B. John Williams, Jr., I.R.S., Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for Respondent-Appellee.

Before HIGGINBOTHAM, DUHÉ and DeMOSS, Circuit Judges.

PATRICK E. HIGGINBOTHAM, Circuit Judge:

Taxpayers appeal the judgment of the United States Tax Court which found that they fraudulently failed to declare and pay tax on approximately $1,280,000 of income.1 The court determined that Robert W. Lisle, along with Claude M. Ballard and Burton W. Kanter, earned the unreported income through an elaborate scheme involving the sale of influence by Lisle and Ballard at Prudential Life Insurance...

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