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CAVALLARO v. C.I.R.

Nos. 15-1368, 15-1376.

842 F.3d 16 (2016)

William CAVALLARO and Patricia Cavallaro, Donors, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

November 18, 2016.

Attorney(s) appearing for the Case

Andrew H. Good , with whom Philip G. Cormier , Good Schneider Cormier , Edward DeFranceschi , DeFranceschi & Klemm, P.C., Jack W. Pirozzolo , Boston, MA, Joseph R. Guerra , Matthew Lerner , Washington, DC, and Sidley Austin LLP were on brief, for appellants.

Caroline D. Ciraolo , Acting Assistant Attorney General, with whom Bruce R. Ellisen , Attorney, Tax Division, U.S. Department of Justice, and Ivan C. Dale , Attorney, Tax Division, U.S. Department of Justice, were on brief, for appellee.

Before Howard, Chief Judge, Lynch and Kayatta, Circuit Judges.

William Cavallaro and his wife Patricia Cavallaro (together, "the Cavallaros") appeal from a Tax Court decision affirming a determination by the Internal Revenue Service ("IRS") Commissioner that they owed gift taxes on a $29,670,000 gift to their sons. After careful consideration, we affirm...

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