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PALAHNUK v. UNITED STATES

No. 2006-5069.

475 F.3d 1380 (2007)

Jonathan PALAHNUK, and Kimberly Palahnuk, Plaintiffs-Appellants, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

February 12, 2007.

Attorney(s) appearing for the Case

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

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.

Before MAYER, BRYSON and DYK, Circuit Judges.

MAYER, Circuit Judge.

Jonathan and Kimberly Palahnuk ("Appellants") appeal from the judgment of the United States Court of Federal Claims that income from stock options was taxable in the year they exercised their options rather than when they paid off the margin loan used to purchase the stock. Palahnuk v. United States, 70 Fed.Cl. 87 (2006). We affirm.

Background

Jonathan Palahnuk ("Palahnuk") entered into two agreements with his...

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