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SUN v. C.I.R.

No. 16-60270.

880 F.3d 173 (2018)

Jerry J. SUN; Sun Nam Sun, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed January 18, 2018.

Attorney(s) appearing for the Case

Carol Ann Cantrell , Cantrell & Cantrell, P.L.L.C., George William Connelly, Esq. , Chamberlain, Hrdlicka, White, Williams & Aughtry, Lynne Liberato , Haynes & Boone, L.L.P., Houston, TX, William Feldman , Attorney, Haynes & Boone, L.L.P., New York, NY, for Petitioners-Appellants.

Geoffrey Klimas , U.S. Department of Justice, Tax Division, Appellate Section, Kathryn Keneally , U.S. Department of Justice, Tax Division, Teresa Ellen McLaughlin , U.S. Department of Justice, Tax Division, Appellate Section, William J. Wilkins , Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before DAVIS, CLEMENT, and COSTA, Circuit Judges.

A friend from overseas sent Jerry Sun and a company Sun controlled about $19 million to invest. Sun used almost $6 million for personal expenses. Another $4 million was kept in the accounts of Sun's company. The remaining $9 million or so was invested, but it was held in brokerage accounts in Sun's name, mingled with...

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