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PERKINS v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 19-2481 August Term 2019.

970 F.3d 148 (2020)

Alice PERKINS, Fredrick Perkins, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: August 12, 2020.

Attorney(s) appearing for the Case

MARGARET A. MURPHY , Hamburg, NY ( Gary D. Borek , Cheektowaga, NY, on the brief), for Petitioners-Appellants.

JACOB CHRISTENSEN , Attorney ( Travis A. Greaves , Deputy Assistant Attorney General, Francesca Ugolini , Attorney, on the brief), for Richard E. Zuckerman , Principal Deputy Assistant Attorney General, Tax Division, U.S. Department of Justice, Washington, DC.

Before: Sack, Wesley, Livingston, Circuit Judges.

Alice Perkins is an enrolled member of the Seneca Nation of Indians (the "Seneca Nation" or the "Nation") who resides on the Seneca Nation's Allegany Territories with her husband, Fredrick.1 Together they operate A & F Trucking, which was involved in the mining and sale of gravel from land...

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