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NELSON v. C.I.R.

No. 20-61068.

17 F.4th 556 (2021)

Mary P. NELSON; James C. Nelson, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

FILED November 3, 2021.

Attorney(s) appearing for the Case

Rachael E. Rubenstein , Farley P. Katz , Clark Hill, P.L.C., San Antonio, TX, Adam Ansari , Clark Hill, P.L.C., Chicago, IL, Jadd Fitzgerald Masso, Esq. , Clark Hill Strasburger, Dallas, TX, for Petitioners Appellants.

Douglas Campbell Rennie , Bethany Buck Hauser, Esq. , Attorney, David A. Hubbert , Jennifer Marie Rubin, Esq. , Francesca Ugolini , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Michael J. Desmond , William M. Paul , Internal Revenue Service, Washington, DC, for Respondent Appellee.

Before KING, SMITH, and HAYNES, Circuit Judges.

Mary P. Nelson and James C. Nelson appeal from the Tax Court's denial of their petition for a redetermination of a deficiency of gift tax issued by the Commissioner of Internal Revenue for the tax years 2008 and 2009. For the following reasons, we AFFIRM.

I. FACTS & PROCEDURAL HISTORY

Mary P. Nelson ("Mary...

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