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SLONE v. C.I.R.

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

788 F.3d 1049 (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.

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 , David R. Jojola and Derek W. Kaczmarek , Silver Law PLC, Scottsdale, AZ, for Petitioners-Appellees.

Before: JOHN T. NOONAN and SANDRA S. IKUTA, Circuit Judges and WILLIAM H. ALBRITTON, III, Senior District Judge.

OPINION

This appeal involves two sales. First, Slone Broadcasting Co. sold essentially all of its assets to Citadel Broadcasting Co. for $45 million. The shareholders of Slone Broadcasting then sold all their shares to Berlinetta, Inc. for $33 million. The substance of the...

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