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U.S. v. BERGBAUER

No. 08-2054.

602 F.3d 569 (2010)

UNITED STATES of America, Plaintiff-Appellee, v. Robert L. BERGBAUER; Marie T. Bergbauer, Defendants-Appellants.

United States Court of Appeals, Fourth Circuit.

Decided: April 16, 2010.

Attorney(s) appearing for the Case

ARGUED: Julian Spirer, Bethesda, Maryland, for Appellants. Francesca Ugolini Tamami, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Mark L. Rosenberg, Bethesda, Maryland, for Appellants. John A. DiCicco, Acting Assistant Attorney General, Kenneth L. Greene, Tax Division, United States Department of Justice, Washington, DC; Rod J. Rosenstein, United States Attorney, Baltimore, Maryland, for Appellee.

Affirmed by published opinion. Judge AGEE wrote the opinion, in which Judge MOTZ and Judge SHEDD joined.

OPINION

AGEE, Circuit Judge:

Robert and Marie Bergbauer appeal from the grant of summary judgment to the Government establishing their federal income tax liability. The district court held that Robert Bergbauer's sale of his interest in a subsidiary of Ernst & Young LLP ("Ernst & Young") was a fully taxable event in the year 2000. For the reasons set forth below, we affirm the judgment of the district...

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