Susan Taylor Martin v. United States

WIENER, Circuit Judge:

In this tax refund suit, Plaintiff-Appellant Susan Taylor Martin (“Susan”) appeals the district court’s order denying her motion for summary judgment and granting the cross-motion for summary judgment of Defendant-Appellee United States of America (the “government”). Concluding that the district court did not err in holding that Susan must recognize gain on the $5.75 million payment she received from Tenneco Gas Louisiana, Inc. (“Tenneco”) 1 for the sale of her claims against her former husband’s bankruptcy estate (the “Estate”), we affirm.

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FACTS AND PROCEEDINGS

Ken…