Michael Tricarichi v. Cir

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS NOV 13 2018 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT MICHAEL A. TRICARICHI, Transferee, No. 16-73418 Petitioner-Appellant, Tax Ct. No. 23630-12 v. MEMORANDUM* COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted February 7, 2018 Pasadena, California Before: W. FLETCHER, BEA,** and OWENS, Circuit Judges. Taxpayer Michael A. Tricarichi appeals from the tax court’s decision on his petition challenging a notice of transferee liability…