United States Fourth Circuit

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US v. Bergbauer, 08-2054

District court's grant of summary judgment in favor of the government establishing defendants' federal tax liability in holding that defendant's sale of his interest in a subsidiary of Ernst & Young LLP was a fully taxable event in the year 2000, is affirmed as both prongs of the "economic reality" test have been satisfied and the district court did not err in so finding.

Appellate Information

  • Decided 04/16/2010
  • Published 04/16/2010



  • United States Fourth Circuit