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CLAY v. C.I.R.

No. 19-14441.

990 F.3d 1296 (2021)

James CLAY, Audrey Osceola, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

March 16, 2021.

Attorney(s) appearing for the Case

Robert O. Saunooke , Saunooke Law Firm, PA, Cherokee, NC, for Petitioners-Appellants.

Robert Joel Brannan , Jacob Earl Christensen , Francesca Ugolini , U.S. Department of Justice, Chief Appellate Section Tax Division, Washington, DC, Michael J. Desmond , Chief Counsel — IRS, Washington, DC, for Respondent-Appellee.

Before WILSON, GRANT, and TJOFLAT, Circuit Judges.

In the late 1980s, the Miccosukee Tribe decided to build a casino in Florida. Acres of land between Miami and the Everglades now host a hotel, a concert hall, a food court, a restaurant, and a gift shop. And, of course, gaming. The casino's profits skyrocketed, and the Tribe chose to share those profits with its members. During...

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