Load v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT LOAD, INC.; COAD, INC.,  Petitioners, No. 07-72564 v.  D.C. No. CIR-1 : 7287-02 COMMISSIONER OF INTERNAL REVENUE, OPINION Respondent.  Appeal from a Decision of the United States Tax Court Stephen J. Swift, Judge, Presiding Argued and Submitted January 14, 2009—San Francisco, California Filed February 2, 2009 Before: Myron H. Bright,* Procter Hug, Jr., and Stephen Reinhardt, Circuit Judges. Per Curiam Opinion *The Honorable Myron H. Bright, Senior United States Circuit Judge for the Eighth Circuit, sitting by designation.…