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McNEILL v. U.S.

No. 15-8095.

836 F.3d 1282 (2016)

Corbin A. McNEILL; Dorice S. McNeill, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

September 6, 2016.

Attorney(s) appearing for the Case

Gordon B. Nash, Jr. , Drinker Biddle & Reath LLP, Chicago, Illinois ( Paul J. Hickey , Hickey & Evans, LLP, Cheyenne, Wyoming, and Gabriel G. Tsui , Leech Tishman Fuscaldo & Lampl, LLC, Oak Brook, Illinois, with him on the briefs), for Petitioners-Appellants.

Michael J. Haungs , Attorney, Appellate Section, Tax Division of the United States Department of Justice, Washington, D.C. ( Caroline D. Ciraolo , Acting Assistant Attorney General, Tax Division, and Diana L. Erbsen , Deputy Assistant Attorney General, Tax Division, and Gilbert S. Rothenberg and Jacob Earl Christensen , Attorneys, Appellate Section, Tax Division of the United States Department of Justice, Washington, D.C., and Christopher A. Crofts , Of Counsel, United States Attorney, District of Wyoming, with him on the brief), for Respondent-Appellee.

Before LUCERO, GORSUCH, and PHILLIPS, Circuit Judges.

After commanding an attack submarine and eventually retiring from the Navy, Corbin McNeill pursued a second career as a utility company executive. It proved a much more lucrative line of work. When he approached his second retirement he found himself slated to receive an $18 million payment. And faced with the promise of...

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