Court of Appeals for the Ninth Circuit June 7, 2007, 04-75716 (George MacIel v. Commissioner of Internal Revenue)

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OPINION

WILLIAM A. FLETCHER, Circuit Judge.

George Maciel appeals from a decision of the United States Tax Court, which upheld an Internal Revenue Service (“IRS”) Notice of Deficiency for the 1990, 1991, and 1992 tax years. In a separate proceeding, Maciel pled guilty to criminal tax charges.