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WATTS v. COMMISSIONER OF IRS

No. 17-15282.

THOMAS E. WATTS, MARY E. WATTS, et al., Petitioners-Appellants, v. COMMISSIONER OF IRS, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

January 10, 2019.

Attorney(s) appearing for the Case

William V. Linne , for Petitioner-Appellant.

David Lee McGee , for Petitioner-Appellant.

Marcus A. Huff , for Petitioner-Appellant.

Patrick J. Urda , for Respondent-Appellee.

Gilbert Steven Rothenberg , for Respondent-Appellee.

Clint A. Carpenter , for Respondent-Appellee.

Joan I. Oppenheimer , for Respondent-Appellee.

Nathaniel S. Pollock , for Respondent-Appellee.

Horace Crump , for Respondent-Appellee.

Edwin B. Cleverdon , for Respondent-Appellee.

William M. Paul , for Respondent-Appellee.

Clint J. Locke , for Respondent-Appellee.

Before WILSON, BRANCH and ANDERSON, Circuit Judges.

DO NOT PUBLISH

On appeal, both parties agree that the Tax Court erred in assuming that Wellspring made an election pursuant to Section 3.4(c) of the Partnership Agreement, which would result in Wellspring being entitled to receive preferred consideration based on the formula set forth in Section 10.9 of the Partnership Agreement that...

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