Third Circuit Allows Defense by Estate for Not Paying Taxes

In 2007 Sir John Thouron died leaving a very large estate. The executor was advised by a tax attorney to not pay all of the large tax bill that came with the large estate. In Estate of Thouron v. US, the Third Circuit Court of Appeals ruled that a reasonable cause defense may be made by the estate due to the reliance on the attorney’s legal advice.

See Richard A. Nessler, United States: Taxpayer May Raise Reasonable Cause Defense to Excuse Late Payment Penalty, Mondaq, June 3, 2014.