
    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.
    No. 2011-5103.
    United States Court of Appeals, Federal Circuit.
    Jan. 12, 2012.
    
      David D. Aughtry, Chamberlain, Hrdlic-ka, White, Williams & Aughtry, of Atlanta, GA, 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.
    Before RADER, Chief Judge, LOURIE and LINN, Circuit Judges.
   JUDGMENT

PER CURIAM.

This Cause having been heard and considered, it is

ORDERED and Adjudged:

AFFIRMED. See Fed. Cir. R. 36.  