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U.S. v. SPOOR TRUSTEE OF LOUIS PAXTON GALLAGHER

No. 15-12877.

838 F.3d 1197 (2016)

UNITED STATES of America, Plaintiff-Appellant, v. F. Gordon SPOOR, as the Personal Representative of the Estate of Louise P. Gallagher, as the TRUSTEE OF the LOUISE PAXTON GALLAGHER REVOCABLE TRUST, Defendant-Appellee, Paxton Media Group, LLC, Intervenor-Appellee.

United States Court of Appeals, Eleventh Circuit.

Date Filed: October 4, 2016.

Attorney(s) appearing for the Case

Rachel Ida Wollitzer , U.S. Department of Justice, Chief Appellate Section Tax Division, Washington, DC, Caroline D. Ciraolo , Chief Counsel-IRS, Washington, DC, Gregory L. Jones , U.S. Department of Justice, Tax Division, Washington, DC, Teresa E. McLaughlin , U.S. Department of Justice, Chief Appellate Section Tax Division, Washington, DC, for Plaintiff-Appellant.

Hala A. Sandridge , Darren Farfante , Buchanan Ingersoll & Rooney, PC, Tampa, FL, for Intervenor-Appellee.

William G. Lazenby , Law Office of Ellison & Lazenby, PLLC, St. Petersburg, FL, Steven L. Brannock , Brannock & Humphries, PA, Tampa, FL, Ceci Berman , Brannock & Humphries, PA, Tampa, FL, for Defendant-Appellee.

Before MARCUS and WILLIAM PRYOR, Circuit Judges, and LAWSON, District Judge.

In this tax case, the United States appeals the district court's determination that commissions claimed by Defendant F. Gordon Spoor as personal representative of the Louise P. Gallagher Estate and as trustee of the Louise Paxton Gallagher Revocable Trust have priority over a special deferred estate tax lien on property designated...

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