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ESTATE OF STREIGHTOFF v. COM'R OF INTERNAL REVENUE

No. 19-60244.

954 F.3d 713 (2020)

ESTATE OF Frank D. STREIGHTOFF, Deceased, Elizabeth Doan Streightoff, Executor, Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed March 31, 2020.

Attorney(s) appearing for the Case

Harold A. Chamberlain , Spring, TX, Michael Christopher Riddle , The Woodlands, TX, for Petitioner-Appellant.

Julie Ciamporcero Avetta , Ellen Page DelSole, Esq. , Trial Attorney, David A. Hubbert , Gilbert Steven Rothenberg, Esq. , Senior Attorney, U.S. Department of Justice, Tax Division, Appellate Section, William M. Paul , Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before HIGGINBOTHAM, STEWART, and ENGELHARDT, Circuit Judges.

Respondent-Appellee the Commissioner of Internal Revenue issued Petitioner-Appellant Estate of Frank D. Streightoff (the "Estate") a notice of deficiency for the Estate's 2012 tax return. The Commissioner determined that the Estate had a $491,750.00 tax liability which differed from the Estate's tax return valuation...

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