Seaview Trading, LLC, Agk Inve v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT SEAVIEW TRADING, LLC, AGK No. 20-72416 INVESTMENTS, LLC, TAX MATTERS PARTNER, Tax Ct. No. Petitioner-Appellant, 1837-11 v. OPINION COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted October 18, 2021 San Francisco, California Filed May 11, 2022 Before: Bridget S. Bade and Patrick J. Bumatay, Circuit Judges, and William K. Sessions III, * District Judge. Opinion by Judge Bumatay; Dissent by Judge Bade * The Honorable William K. Sessions III, United…