Patients Mutual Assistance v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT PATIENTS MUTUAL ASSISTANCE No. 19-73078 COLLECTIVE CORPORATION, DBA Harborside Health Center, Tax Ct. Nos. Petitioner-Appellant, 29212-11 30851-12 v. 14776-14 COMMISSIONER OF INTERNAL REVENUE, OPINION Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted February 9, 2021 San Francisco, California Filed April 22, 2021 Before: Andrew D. Hurwitz and Daniel A. Bress, Circuit Judges, and Clifton L. Corker, * District Judge. Opinion by Judge Bress * The Honorable Clifton L. Corker, United…