Michael Tricarichi v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT MICHAEL A. TRICARICHI, Transferee, No. 16-73418 Petitioner-Appellant, Tax Ct. No. v. 23630-12 COMMISSIONER OF INTERNAL REVENUE, OPINION Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted February 7, 2018 Pasadena, California Filed November 13, 2018 Before: William A. Fletcher, Carlos T. Bea, * and John B. Owens, Circuit Judges. Opinion by Judge Owens * Judge Bea was drawn to replace Judge Reinhardt on the panel following his death. Ninth Circuit General Order 3.2h. Judge Bea has…