Gail Vento LLC v. United States, No. 09-03, 2013 U.S. Dist. LEXIS 48472 (D. V.I. Apr. 1, 2013)

(case involved transfer of LLC interests; LLC owned stock in closely held corporation; corporation sold its stock on Nov. 24 and LLC owners sold their interests to three corporations in Cayman Islands in exchange for annuities on same day; stock sale publicly announced on Nov. 27 with closing on Jan. 8; court determined that sale of LLC interests subject to assignment of income doctrine such that gains from sale of corporate stock taxable to LLC owners; court based opinion on Ferguson v. Comr., 174 F.3d 997 (9th Cir. 1999); basic principle involved is that appreciated property transferred where transferee sells the property, any resulting gain taxed to original transferor if original transfer is too close in time to date property sold).