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McCLENDON v. U.S.

No. 17-20174.

892 F.3d 775 (2018)

Gail McCLENDON, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed June 14, 2018.

Attorney(s) appearing for the Case

Steven Jon Knight , Lawrence W. Sherlock, Esq. , Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, TX, for Plaintiff-Appellant.

Marion E. M. Erickson , Bruce Raleigh Ellisen , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Jon E. Fisher , U.S. Department of Justice, Tax Division, Dallas, TX, for Defendant-Appellee.

Before DAVIS, JONES, and HIGGINSON, Circuit Judges.

Gail McClendon appeals the district court's summary judgment determining that her late husband, Dr. Robert McClendon ("McClendon"), was personally liable under 26 U.S.C. § 6672 for over $4.3 million in penalties for the unpaid withholding taxes of his medical practice. She also appeals the district court's subsequent...

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