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BLACK & DECKER CORP. v. U.S.

No. 05-1015.

436 F.3d 431 (2006)

The BLACK & DECKER CORPORATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided February 2, 2006.

Attorney(s) appearing for the Case

ARGUED: Richard Farber, United States Department of Justice, Tax Division, Washington, D.C., for Appellant. Herbert Odell, Miller & Chevalier, Chartered, Bala Cynwyd, Pennsylvania, for Appellee. ON BRIEF: Eileen J. O'Connor, Assistant Attorney General, Richard T. Morrison, Deputy Assistant Attorney General, Allen F. Loucks, United States Attorney, Gilbert S. Rothenberg, Bridget M. Rowan, Deborah K. Snyder, Tax Division, United States Department of Justice, Washington, D.C., for Appellant. Philip Karter, Miller & Chevalier, Chartered, Bala Cynwyd, Pennsylvania; Laura G. Ferguson, Miller & Chevalier, Chartered, Washington, D.C.; Harry A. Pogash, Darren G. Pratt, The Black & Decker Corporation, Towson, Maryland; John E. McCann, Jr., Miles & Stockbridge, P.C., Baltimore, Maryland, for Appellee.

Before LUTTIG, WILLIAMS, and MICHAEL, Circuit Judges.

Affirmed in part, reversed in part, and remanded by published opinion. Judge MICHAEL wrote the opinion, in which Judge LUTTIG and Judge WILLIAMS joined.

OPINION

MICHAEL, Circuit Judge.

A corporate taxpayer paid $561 million to a controlled subsidiary in exchange for 10,000 shares of the subsidiary's stock and the subsidiary's assumption of a $560 million contingent liability of the taxpayer. The taxpayer then sold the shares for $1 million, claimed...

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