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JADE TRADING, LLC, BY AND THROUGH, ROBERT W. ERWIN AND LAURA KAVANAUGH ERVIN, ON BEHALF OF ERVIN CAPITAL, LLC, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, Plaintiffs-Appellees, v. UNITED STATES, Defendant-Appellant.

PER CURIAM

NOTE: This disposition is nonprecedential.



Appeal from the United States Court of Federal Claims in No. 03-CV-2164, Judge Mary Ellen Coster Williams.

JUDGMENT

DAVID D. AUGHTRY, Chamberlain, Hrdlicka, White, Williams & Aughtry, of Atlanta, Georgia, argued for plaintiffs-appellees. With him on the brief was LINDA S. PAINE.

JOAN I. OPPENHEIMER, Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellant. With her on the brief were GILBERT S. ROTHENBERG, Acting Deputy Assistant Attorney General, and RICHARD FARBER, Attorney.

THIS CAUSE having been heard and considered, it is

ORDERED AND ADJUDGED:

PER CURIAM (RADER, Chief Judge, LOURIE and LINN, Circuit Judges).

AFFIRMED. See Fed. Cir. R. 36.

ENTERED BY ORDER OF THE COURT

Date

______________________


Jan Horbaly


Clerk


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Jade Trading, LLC v. United States
(Jan 12, 2012)