United States Tenth Circuit
TRUE v. COMM'R OF INTERNAL REVENUE, 02-9010
In a challenge to defendant-IRS's tax deficiency determinations concerning the transfer of interests in family businesses subject to buy-sell agreements, the district court did not clearly err in concluding that plaintiffs could not be excused from the tax penalty.
Appellate Information
- Decided 12/03/2004
- Published 12/03/2004
Judges
- SEYMOUR, Circuit Judge., Before SEYMOUR, Circuit Judge, PORFILIO, Senior Circuit Judge, and MURPHY, Circuit Judge.
Court
- United States Tenth Circuit
Counsel
- For Appellant:
- Buford P. Berry (Mary A. McNulty and Katherine Quigley, Thompson & Knight L.L.P., and Ronald M. Morris, Casper, WY, with him on the briefs), Thompson & Knight L.L.P., Dallas, TX, for Petitioners-Appellants.
- For Appellees:
- Joan I. Oppenheimer, Attorney, Tax Division, Department of Justice (Eileen J. O'Connor, Assistant Attorney General, and Jonathan S. Cohen, Attorney, Tax Division, Department of Justice, with her on the briefs), Washington, DC, for Respondent-Appellee.