United States Fifth Circuit

Summary judgment for the government on taxpayers' claim to recover income taxes erroneously assessed is affirmed where a taxable transfer occurred on the date certain options were exercised, not the date on which a margin loan was repaid.

Appellate Information

• Decided 01/09/2007
• Published 01/10/2007

Judges

• EDITH H. JONES, Chief Judge:, Before JONES, Chief Judge, and DAVIS and GARZA, Circuit Judges.

Court

• United States Fifth Circuit

Counsel

• For Appellant:
  
• Don Paul Badgley (argued), Badgley-Mullins Law Group, Seattle, WA, for Plaintiffs-Appelants., Anthony T. Sheehan (argued), Robert W. Metzler, U.S. Dept. of Justice, Tax Div., App. Section, Washington, DC, for U.S.