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CRI-LESLIE, LLC v. COMMISSIONER OF INTERNAL REVENUE

No. 16-17424.

882 F.3d 1026 (2018)

CRI-LESLIE, LLC, Donald W. Wallace, Tax Matters Partner, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

February 15, 2018.

Attorney(s) appearing for the Case

Charles A. Carlson , Leslie J. Barnett , Christopher Dingman , Micah G. Fogarty , David L. Koche , Barnett Bolt Kirkwood Long & Koche, Tampa, FL, for Petitioner-Appellant.

Deborah K. Snyder , Teresa E. McLaughlin , U.S. Department of Justice, Chief Appellate Section Tax Division, Washington, DC, Timothy A. Sloane , Andrew Michael Tiktin , Miami, FL, William J. Wilkins , Chief Counsel—IRS, Washington, DC, for Respondent-Appellee.

Before MARCUS and NEWSOM, Circuit Judges, and BUCKLEW, District Judge

More than 40 years ago, Judge Henry Friendly lamented that "[t]he problem with respect to the tax treatment of payments for the termination of contract rights having a property flavor is among the most frustrating in income tax law." Sirbo Holdings, Inc. v. Comm'r, 509 F.2d 1220, 1223...

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