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MARVEL ENTERTAINMENT, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 15-3335-ag August Term 2016.

842 F.3d 1291 (2016)

MARVEL ENTERTAINMENT, LLC, as Successor to Marvel Entertainment, Inc., F.K.A. Marvel Enterprises, Inc. and as agent for members of Marvel Enterprises, Inc. and Subsidiaries Group, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: September 7, 2016.

Attorney(s) appearing for the Case

B. JOHN WILLIAMS, JR . ( David W. Foster , Nathan P. Wacker , Sonja Schiller , on the brief), Skadden, Arps, Slate, Meagher & Flom LLP, Washington, D.C. and Chicago, Illinois, for Petitioner-Appellant.

DEBORAH K. SNYDER ( Gilbert S. Rothenberg , Thomas J. Clark , on the brief), Tax Division, Department of Justice, for Caroline D. Ciraolo , Acting Assistant Attorney General, and Diana L. Erbsen , Deputy Assistant Attorney General, Washington D.C., for Respondent-Appellee.

Before: Winter, Chin, and Droney, Circuit Judges.

This appeal challenges an opinion and an order and decision of the United States Tax Court entered July 21, 2015 granting summary judgment for the Commissioner of Internal Revenue. The sole issue before the Tax Court, and before us on appeal, is whether petitioner-appellant Marvel Entertainment, LLC's consolidated group must reduce its consolidated...

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