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DAVIS v. C.I.R.

Nos. 12-10916, 12-11786, 12-11787 and 12-11788.

716 F.3d 560 (2013)

Allen L. DAVIS, Petitioner-Appellant, v. COMMISSIONER OF IRS, Respondent-Appellee. J. David Rosenberg, Diane M. Rosenberg, Petitioners-Appellees, v. Commissioner of IRS, Respondent-Appellant. Jared A. Davis, Bridget Davis, Petitioners-Appellees, v. Commissioner of IRS, Respondent-Appellant. A. David Davis, Tracy Davis, Petitioners-Appellees, v. Commissioner of IRS, Respondent-Appellant.

United States Court of Appeals, Eleventh Circuit.

May 16, 2013.

Attorney(s) appearing for the Case

David Boris Rivkin , Andrew M. Grossman , Jeffrey Henry Paravano , Baker & Hosteller, LLP, Washington, DC, for Petitioner-Appellant in No. 12-10916.

Kenneth W. Gideon , David William Foster , Melissa L. Galetto , Daniel P. Phillips , Arnette A. Steele , Albert Hanauer Turkus , Skadden, Arps, Slate, Meagher & Flom, LLP, Washington, DC, Julia Kazaks, Skadden Arns. Palo Alto. CA. for Petitioners-Appellees in Nos. 12-11786, 12-11787 and 12-11788.

Ellen Page DelSole , Jonathan S. Cohen , Gilbert Steven Rothenberg , Tamara W. Ashford , U.S. Dept. of Justice, Tax Div., App. Section, William J. Wilkins , Mehssa C. Liquerman , Chief Counsel — IRS, Robert R. Di Trolio , U.S. Tax Court, Washington, DC, Gretchen Ann Kindel , Cincinnati, OH, for Respondent-Appellee.

Before BARKETT, JORDAN and RIPPLE, Circuit Judges.

RIPPLE, Circuit Judge.

In 2004, Allen Davis exercised an option to purchase additional shares in CNG Financial Corporation ("CNG"), a closely-held corporation. He did not report his exercise of the option as income on his federal income tax return, believing that it had no tax consequences. However, CNG took a deduction for the value of the shares Mr. Davis received through the option's exercise, stating that it issued the option to Mr. Davis in connection with his...

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