IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT United States Court of Appeals Fifth Circuit

FILED March 31, 2020 No. 19-60244 Lyle W. Cayce Clerk ESTATE OF FRANK D. STREIGHTOFF, DECEASED, Elizabeth Doan Streightoff, Executor,

Petitioner - Appellant v. COMMISSIONER OF INTERNAL REVENUE,

Respondent - Appellee

Appeal from the Decision of the United States Tax Court

Before HIGGINBOTHAM, STEWART, and ENGELHARDT, Circuit Judges. CARL E. STEWART, Circuit Judge: 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 wh