Michael Brown v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT MICHAEL D. BROWN, No. 22-70001 Petitioner-Appellant, Tax Court. No. 18104-17L v. COMMISSIONER OF INTERNAL OPINION REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted November 10, 2022 Pasadena, California Filed January 24, 2023 Before: Mary H. Murguia, Chief Judge, and Barrington D. Parker, * and Kenneth K. Lee, Circuit Judges. Opinion by Judge Parker * The Honorable Barrington D. Parker, United States Circuit Judge for the U.S. Court of Appeals for the Second Circuit,…