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CAVANAUGH v. COMMISSIONER OF INTERNAL REVENUE

No. 18-60299, Consolidated with No. 18-60304.

JAMES A. CAVANAUGH, JR., Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed: March 29, 2019.

Attorney(s) appearing for the Case

Richard Bradshaw Farber , for Respondent-Appellee.

James Allen Moseley , for Petitioner-Appellant.

George Tomas Rhodus , for Petitioner-Appellant.

Gilbert Steven Rothenberg , for Respondent-Appellee.

Bethany Buck Hauser , for Respondent-Appellee.

Patrick Joseph Urda , for Respondent-Appellee.

Angela Laughlin Brown , for Petitioner-Appellant.

William M. Paul , for Respondent-Appellee.

David A. Hubbert , Tax Court, for Respondent-Appellee.

Before: CLEMENT, GRAVES, and OLDHAM, Circuit Judges.

This case requires us to answer the question whether a settlement payment to avoid liability arising from the death of a sole shareholder's girlfriend is a deductible business expense for his S corporation. The IRS and Tax Court have said it is not. We affirm.

FACTS AND PROCEEDINGS

James Cavanaugh...

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