Celia Mazzei v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT CELIA MAZZEI; ANGELO L. MAZZEI; No. 18-72451 MARY E. MAZZEI, Petitioners-Appellants, Tax Ct. Nos. 16702-09 v. 16779-09 COMMISSIONER OF INTERNAL REVENUE, OPINION Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted February 14, 2020 Pasadena, California Filed June 2, 2021 Before: Jay S. Bybee and Daniel P. Collins, Circuit Judges, and Barry Ted Moskowitz, * District Judge. Opinion by Judge Collins * The Honorable Barry Ted Moskowitz, United States District Judge for the Southern…