Court of Appeals for the Ninth Circuit October 2, 2017, 16-72590 (McWhinney v. Commissioner)

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS OCT 2 2017

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

SEAN C. McWHINNEY; CONNIE No. 16-72590

PEDERSEN,

Tax Ct. No. 19464-15

Petitioners-Appellants,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.