United States Federal Circuit

Summary judgment for the government in a tax dispute is affirmed where the district court did not err in finding that plaintiffs-taxpayers' income from certain stock options was taxable in the year they exercised their options rather than when they paid off a margin loan used to purchase the stock.

Appellate Information

• Decided 02/12/2007
• Published 02/12/2007

Judges

• MAYER, Circuit Judge., Before MAYER, BRYSON and DYK, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Don Paul Badgley, Badgley-Mullins Law Group, of Seattle, Washington, argued for plaintiffs-appellants.


• For Appellees:
  
• Joan I. Oppenheimer, Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee.   With her on the brief were Eileen J. O'Connor, Assistant Attorney General, and Richard Farber, Attorney.