Solomon Blatt, Jr., as of the Estate of Solomon Blatt v. United States

Affirmed by published opinion. Judge NIEMEYER wrote the opinion, in which Judge MURNAGHAN and Senior Judge HARVEY joined.

OPINION

NIEMEYER, Circuit Judge:

Solomon Blatt, Jr., as executor of the estate of Solomon Blatt, Sr., his father, paid $155,000 to the IRS in August 1987 in respect of the estate’s income taxes due for the tax year that ended April 30, 1987. The actual amount of the tax due had not been computed, and Blatt remitted what he believed in good faith would be an amount sufficient to cover what was owed. A year later, in August 1988, Blatt filed a fiduciary income tax return…