Court of Appeals for the Ninth Circuit October 3, 2017, 16-72868 (Christen v. Commissioner)

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS OCT 3 2017

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

MICHAEL C. CHRISTEN, No. 16-72868

Petitioner-Appellant, Tax Ct. No. 16147-14

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the

United States Tax Court

Submitted September 26, 2017**

Before: SILVERMAN, TALLMAN, and N.