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LINDSAY v. UNITED STATES

No. 20-50994.

4 F.4th 292 (2021)

Jeffery Allen LINDSAY, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

FILED July 9, 2021.

Attorney(s) appearing for the Case

John Edward Leeper , El Paso, TX, for Plaintiff-Appellant.

Allison Turbiville , Joan I. Oppenheimer , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, for Defendant-Appellee.

Before Higginbotham, Stewart, and Wilson, Circuit Judges.

Jeffery Allen Lindsay sued the Internal Revenue Service ("the IRS") to recover penalties that he paid for filing late tax returns and making late tax payments for the 2012-2015 tax years. Lindsay's suit alleged that he was entitled to the "reasonable cause" exception to the...

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