David S. v. United States

MEMORANDUM AND OPINION

CHRISTINE O.C. MILLER, Judge.

This case, before the court after trial, arises from the failure of individual and corporate taxpayers to report one consistent value for almost 10 million shares of restricted stock issued in February 2000 to plaintiffs-counterdefendants David S. Litman and Malia A. Litman (collectively, the “Litmans”) and Robert B. Diener and Michelle S. Diener (collectively, the “Dieners”).1 Messrs. Lit-*92man and Diener are the founders of Hotels.com, Inc. & Subsidiaries’s two predecessor companies, TMF, Inc. (“TMF”) and HRN Marketing Corp. (“HRN Marketing”).