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ESTATE OF LISLE v. C.I.R.

Nos. 07-60862, 07-60863 and 07-60864.

541 F.3d 595 (2008)

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.

August 25, 2008.

Attorney(s) appearing for the Case

Vester T. Hughes, Jr. (argued), Robert Edwin Davis, Danny S. Ashby (argued), Christopher Donald Kratovil, K & L Gates LLP, Dallas, TX, for Petitioners-Appellants and Appellants.

Joan I. Oppenheimer (argued), Kenneth L. Greene, Richard Thane Morrison, Deputy Asst. Atty. Gen., U.S. Dept. of Justice, Tax Div. App. Section, Gilbert S. Rothenberg, U.S. Dept. of Justice, Robert R. Di Trolio, U.S. Tax Court, Donald L. Korb, Chief Counsel, I.R.S., Washington, DC, for Respondent-Appellee.

Before HIGGINBOTHAM, DAVIS and BARKSDALE, Circuit Judges.

W. EUGENE DAVIS, Circuit Judge:

This case returns to this court for the second time for review of the Tax Court's judgment that taxpayers Robert W. Lisle and his wife Donna M. Lisle1 failed to declare and pay income tax on approximately $1,280,000 in revenue earned as a result of Robert Lisle's relationship with a series of real estate deals and related transactions. See Estate of Robert W. Lisle v. Comm'r, 341 F...

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