Court of Appeals for the Ninth Circuit January 12, 2018, 15-73819 (Duggan v. Commissioner)

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

PHILIP A. DUGGAN, No. 15-73819

Petitioner-Appellant,

Tax Ct. No.

v. 4100-15 L

COMMISSIONER OF INTERNAL

REVENUE, OPINION

Respondent-Appellee.

Appeal from a Decision of the

United States Tax Court

Submitted December 7, 2017*

Seattle, Washington

Filed January 12, 2018

Before: Michael Daly Hawkins, M.