Cir v. Dunkin

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT COMMISSIONER OF INTERNAL  REVENUE, No. 05-76004 Petitioner-Appellant, v.  Tax Ct. No. 4448-03 JOHN MICHAEL DUNKIN, OPINION Respondent-Appellee.  Appeal from a Decision of the United States Tax Court Argued and Submitted June 13, 2007—Pasadena, California Filed August 31, 2007 Before: Dorothy W. Nelson, Stephen Reinhardt, and Pamela Ann Rymer, Circuit Judges. Opinion by Judge D.W. Nelson; Dissent by Judge Reinhardt 11131 COMMISSIONER OF IR v. DUNKIN 11133 COUNSEL Deborah K. Snyder and Richard Farber, United States Depart-…