Commissioner of IRS v. Estate of Travis L. Sanders

ANDERSON, Circuit Judge:

Respondent-Appellant Commissioner of the Internal Revenue Service (the “Commissioner”) appeals the United States Tax Court’s judgment in favor of Petitioners-Appellees the estate of Travis L. Sanders (the “Estate”) and the Government of the United States Virgin Islands. The Commissioner argues that the Tax Court erred by failing to make necessary factual findings. After review, and with the benefit of oral argument, we vacate the Tax Court’s judgment and remand.

The United States of America and the United States Virgin Islands (“USVI”) operate “separate but interrelated…