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PALMER RANCH HOLDINGS LTD. v. C.I.R.

No. 14-14167.

812 F.3d 982 (2016)

PALMER RANCH HOLDINGS LTD, Palmer Ranch Holdings, Inc., Tax Matters Partner, Petitioners-Appellants Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee Cross-Appellant.

United States Court of Appeals, Eleventh Circuit.

February 5, 2016.

Attorney(s) appearing for the Case

Debra J. Albin-Riley , Arent Fox, LLP, Los Angeles, CA, Mark F. Hearne, II , Meghan Sue Largent , Arent Fox, LLP, Clayton, MO, for Petitioners-Appellants Cross-Appellees.

Patrick J. Urda , Gilbert Steven Rothenberg , Francesca Ugolini , U.S. Department of Justice, William J. Wilkins , Chief Counsel-IRS, Washington, DC, for Respondent-Appellee Cross-Appellant.

Before ROSENBAUM and JULIE CARNES, Circuit Judges, and GOLDBERG, Judge.

As recently as 2007, Southwestern Florida served as a proud home to the American, or bald, eagle. One bald eagle nest, SA-010, was located on the eastern side of an 82.19 acre parcel of land known as B-10, in Sarasota County. To the west of B-10 lies Sarasota Bay, where the eagles would fly to feed. To allow the eagles to reach...

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