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SLONE v. C.I.R.

Nos. 16-73349, 16-73351, 16-73354, 16-73356.

896 F.3d 1083 (2018)

Norma L. SLONE, Transferee, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant. Slone Family GST Trust, UA Dated, August 6, 1998, Transferee, D. Jack Roberts, Trustee, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant. James C. Slone, Transferee, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant. Slone Revocable Trust, UA Dated September 20, 1994, Transferee, James C. Slone and Norma L. Slone, Trustees, Petitioner-Appellee, v. Commissioner of Internal Revenue, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed July 24, 2018.

Attorney(s) appearing for the Case

Arthur T. Catterall (argued), Francesca Ugolini , and Gilbert S. Rothenberg , Attorneys; David A. Hubbert , Acting Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellant.

Stephen E. Silver (argued) and Jason M. Silver , Silver Law PLC, Scottsdale, Arizona, for Petitioners-Appellees.

Before: Mary M. Schroeder and Paul J. Watford, Circuit Judges, and William K. Sessions III, District Judge.

OPINION

These consolidated appeals by the Commissioner of Internal Revenue from the Tax Court involve the Commissioner's efforts to hold Petitioners, the former shareholders of a close corporation, Slone Broadcasting Co. ("Slone Broadcasting"), responsible for taxes owed on the proceeds of its 2001 sale of assets...

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