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ESTATE OF ELKINS v. C.I.R.

No. 13-60472.

767 F.3d 443 (2014)

ESTATE OF James A. ELKINS, Jr., Deceased; Margaret Elise Joseph, and Leslie Keith Sasser, Independent Executors, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

September 15, 2014.

Attorney(s) appearing for the Case

Harry Max Reasoner, Esq. , Juliana Denise Hunter , Jeremy Charles Marwell , Stacey Neumann Vu, Esq. , Vinson & Elkins, L.L.P., Houston, TX, Donald Frederick Wood , Vinson & Elkins, L.L.P., Austin, TX, for Petitioners-Appellants.

Arthur Thomas Catterall , Jonathan S. Cohen , Kathryn Keneally , U.S. Department of Justice, William J. Wilkins , Internal Revenue Service, Washington, DC, for Respondents-Appellee.

Before STEWART, Chief Judge, and WIENER and COSTA, Circuit Judges.

WIENER, Circuit Judge:

Petitioners-Appellants Margaret Elise Joseph and Leslie Keith Sasser ("Petitioners"), as Independent Executors of the Estate of their deceased father, James A. Elkins, Jr. ("Decedent"), petitioned the United States Tax Court ("Tax Court") to review and eventually eliminate the federal estate tax deficiency assessed against the Estate by Respondent-Appellee, the Commissioner of Internal Revenue ("the...

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