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SLONE v. C.I.R.

Nos. 12-72464, 12-72495, 12-72496, 12-72497.

810 F.3d 599 (2015)

James C. SLONE; Norma L. Slone; Slone Revocable Trust; UA Dated September 20, 1994; Transferee, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant. Norma L. Slone, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant. Slone Family GST Trust, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant. James C. Slone, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed June 8, 2015.

Amended August 28, 2015.

Attorney(s) appearing for the Case

Arthur T. Catterall (argued) and Francesca Ugolini (argued), Assistant United States Attorneys; Kathryn Keneally , Assistant Attorney General; Tamara W. Ashford , Deputy Assistant Attorney General; Gilbert S. Rothenberg and Kenneth L. Greene , Attorneys, Tax Division, United States Department of Justice, Washington, D.C., for Respondent-Appellant.

Stephen E. Silver (argued), Jason M. Silver , and David R. Jojola , Silver Law PLC, Scottsdale, Arizona, for Petitioners-Appellees.

Opinion by Judge IKUTA; Partial Concurrence and Partial Dissent by Judge NOONAN.

ORDER

The opinion filed June 8, 2015, and appearing at 788 F.3d 1049, is hereby amended as follows:

On page 1053, the second sentence of the penultimate paragraph and the final paragraph should be deleted and replaced with the following:

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