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VISION INFORMATION SERVICES, LLC. v. C.I.R.

No. 04-2110.

419 F.3d 554 (2005)

VISION INFORMATION SERVICES, L.L.C., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: August 22, 2005.

Attorney(s) appearing for the Case

ARGUED: Robert M. Jackson, Honigan, Miller, Schwartz & Cohn, Detroit, Michigan, for Appellant. Steven W. Parks, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Robert M. Jackson, Roger Cook, James H. Combs, Honigan, Miller, Schwartz & Cohn, Detroit, Michigan, for Appellant. Steven W. Parks, Richard Farber, United States Department of Justice, Washington, D.C., for Appellee.

Before: MOORE and COLE, Circuit Judges; WISEMAN, District Judge.

OPINION

KAREN NELSON MOORE, Circuit Judge.

This is an appeal from a decision of the United States Tax Court holding that certain sums received by the Petitioner-Appellant, Vision Information Services, L.L.C. ("Vision" or the "taxpayer"), during tax years 1995 and 1996 were license fees and therefore taxable as ordinary income under the Internal Revenue Code. The legal issue presented in this case is whether the agreement between the taxpayer and Twentieth...

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