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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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