Court of Appeals for the Ninth Circuit August 21, 2006, 04-74624 (Janis v. Commissioner of Internal Revenue)

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

CONRAD JANIS; MARIA G. JANIS, 

Petitioners-Appellants, No. 04-74624

v.

 Tax Ct. No.

01-14318

COMMISSIONER OF INTERNAL

REVENUE, OPINION

Respondent-Appellee.



Appeal from a Decision of the

United States Tax Court

Argued and Submitted

June 6, 2006—Pasadena, California

Filed August 21, 2006

Before: Stephen Reinhardt, Stephen S.