The IRS wants $3.2 billion to cover back taxes that it says are owed by a prominent Texas businessman and his late brother who the IRS says hid income by setting up overseas trust funds.

The Internal Revenue Service detailed its claim in documents filed Wednesday in U.S. Bankruptcy Court in Dallas. It seeks to recover more than $2 billion in unpaid income taxes, interest and penalties from Sam Wyly and more than $1.2 billion from the estate of his brother, Charles Wyly.

The late Charles Wyly, who died in a 2011 car wreck in Aspen, Colorado, was the billionaire who donated $20 million to build the landmark theater bearing his and his wife’s namesake in the AT&T Performing Arts Center in Dallas.

Stewart Thomas, a lawyer for the Wylys, called the IRS claims “unfair and absurd.”

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