Snj Limited v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT SNJ LIMITED; RITCHIE N. STEVENS; No. 20-70902 JULIE A. KEENE-STEVENS, Petitioners-Appellants, Tax Ct. No. 11284-18 v. COMMISSIONER OF INTERNAL OPINION REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted November 17, 2021 Pasadena, California Filed March 10, 2022 Before: Jay S. Bybee and Mark J. Bennett, Circuit Judges, and Joseph F. Bataillon, * District Judge. Opinion by Judge Bennett; Concurrence by Judge Bataillon * The Honorable Joseph F. Bataillon, United States…