No. 15-12582.

834 F.3d 1269 (2016)

COMMISSIONER OF IRS, Petitioner-Appellant, v. ESTATE OF Travis L. SANDERS, Deceased, Thomas S. Hogan, Jr., Personal Representative, Government of the United States Virgin Islands, Respondents-Appellees.

United States Court of Appeals, Eleventh Circuit.

Date Filed: August 24, 2016.

Attorney(s) appearing for the Case

Ellen Page DelSole , Judith Ann Hagley , Gilbert Steven Rothenberg , Francesca Ugolini, U.S. Department of Justice, Chief Appellate Section Tax Division, Ricardo A. Cadenas , Caroline D. Ciraolo , William J. Wilkins , Chief Counsel-IRS, Washington, DC, Anne M. Craig , U.S. Attorney's Office, Lauren B. Epstein , Internal Revenue Service, Christopher Pavilonis , Pavilonis Law Offices, PA, Jacksonville, FL, for Petitioner-Appellant.

David Scott Barnhill , William Morris Sharp , Matthew A. Cullen , Sharp Partners, PA, Tampa, FL, V. Jean Owens , Owens Law Group, PA, Ruskin, FL, Geoffrey P. Eaton , Winston & Strawn, LLP, Washington, DC, for Respondents-Appellees.

Before JORDAN and ANDERSON, Circuit Judges, and DALTON, District Judge.

Respondent-Appellant Commissioner of the Internal Revenue Service (the "Commissioner") appeals the United States Tax Court's judgment in favor of Petitioners-Appellees the estate of Travis L. Sanders (the "Estate") and the Government of the United States Virgin Islands. The Commissioner argues that the Tax Court erred by...

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