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BILLHARTZ v. C.I.R.

No. 14-1216.

794 F.3d 794 (2015)

Marcia BILLHARTZ, Executor of the Estate of Warren Billhartz, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 23, 2015.

Attorney(s) appearing for the Case

Philip D. Speicher , Attorney, Mathis Marifian & Richter LTD, Belleville, IL, for Petitioner-Appellant.

Carol A. Barthel , Attorney, Gilbert S. Rothenberg , Deputy Assistant Attorney General, Department of Justice of the Attorney General, Washington, DC, for Respondent-Appellee.

Before FLAUM, KANNE, and SYKES, Circuit Judges.

Warren Billhartz left over $20 million to his four children when he died. When his Estate filed its estate tax return with the IRS, it claimed a deduction for a large portion of that amount — over $14 million. The IRS disallowed the deduction in full and issued the estate a notice of deficiency. The Estate then petitioned...

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