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ESTATE OF McKELVEY v. C.I.R.

Docket No. 17-2554 August Term 2017.

906 F.3d 26 (2018)

ESTATE OF Andrew J. McKELVEY, Deceased, Bradford G. Peters, Executor, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Second Circuit.

Decided: September 26, 2018.

Attorney(s) appearing for the Case

Clint A. Carpenter , ( David A. Hubbert , Deputy Asst. Atty. General, Gilbert S. Rothenberg , Joan I. Oppenheimer , on the brief), Tax Division, Appellate Section, U.S. Dep't. of Justice, Washington, D.C., for Respondent-Appellant Commissioner of Internal Revenue.

Mark D. Lanpher , ( Robert A. Rudnick , Kristen M. Garry , on the brief), Shearman & Sterling LLP, Washington, D.C., for Petitioner-Appellee Estate of Andrew J. McKelvey.

Before: NEWMAN, CABRANES, and CARNEY, Circuit Judges.

This appeal concerns somewhat unusual financial instruments known as variable prepaid forward contracts ("VPFCs"). A VPFC is an agreement between a short party (typically, the shareholder of a large quantity of low-basis, appreciated stock) and a long party (typically an investment...

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