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KELLER v. U.S.

No. 10-41311.

697 F.3d 238 (2012)

Thomas Lane KELLER, Co-Independent Executor of the Estate of Maude Williams, Deceased; Ann Harithas, Co-Independent Executor of the Estate of Maude Williams, Deceased; Steven Craig Anderson, Co-Independent Executor of the Estate of Maude Williams, Deceased, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

September 25, 2012.

Attorney(s) appearing for the Case

William R. Cousins, III (argued), Robert Don Collier , Todd Allen Kraft , Kathryn Walker Lyles , Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., Dallas, TX, for Plaintiffs-Appellees.

Ellen Page DelSole , Trial Atty. (argued), Tamara W. Ashford , Dep. Asst. Atty. Gen., Jonathan S. Cohen , U.S. Dept. of Justice, Tax Div., App. Sec., Gilbert Steven Rothenberg , Dep. Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for Defendant-Appellant.

Before JONES, Chief Judge, and PRADO and SOUTHWICK, Circuit Judges.

EDITH H. JONES, Chief Judge:

Maude Williams passed away in May 2000, leaving behind both a substantial fortune and incomplete estate-planning documents. Originally believing this omission precluded transfer of the relevant estate property to a limited partnership, her Estate paid over $147 million in federal taxes. The Estate later discovered Texas state authorities supporting that Williams sufficiently capitalized the limited...

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