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LINTON v. U.S.

No. 09-35681.

630 F.3d 1211 (2011)

William A. LINTON; Stacy A. Linton, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed January 21, 2011.

Attorney(s) appearing for the Case

Cory L. Johnson , Seattle, WA, for the appellants.

Jonathan S. Cohen , Department of Justice, Washington, D.C., for the appellee.

Before: JOHN T. NOONAN, DAVID R. THOMPSON and MARSHA S. BERZON, Circuit Judges.

OPINION

PER CURIAM:

Taxpayers William A. Linton and Stacy A. Linton appeal the district court's grant of summary judgment in favor of the United States on their claim for a refund of 2003 federal gift taxes. The Lintons contend that they gifted interests in a limited liability company ("LLC"); the government contends that they gifted cash, securities, and real property. We have jurisdiction under 28 U.S.C. § 1291, and we reverse and remand for further...

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